Unpublished Price Sensitive Information (UPSI)
Information relating to a listed company that is not generally available and, if generally available, would materially affect the price of its securities. Governed by SEBI PIT Regulations 2015.
UPSI is defined in Regulation 2(1)(n) of the SEBI (Prohibition of Insider Trading) Regulations 2015 as "any information, relating to a company or its securities, directly or indirectly, that is not generally available which upon becoming generally available, is likely to materially affect the price of the securities." The Fifth Amendment 2023 introduced a codified 16-item UPSI list — financial results, dividends, changes in capital structure, mergers/de-mergers/acquisitions/disposals/listings of securities, changes in key managerial personnel, and material events under LODR Reg 30.
Every listed entity must maintain a Structured Digital Database (SDD) recording every instance of UPSI sharing — with whom, when, for what purpose. The SDD must be tamper-proof, time-stamped, and available for SEBI inspection. The 21 April 2025 SEBI circular introduced automated PAN freeze for trading window violations, which means non-compliance is enforced through system-level restrictions on the depositories, not just penalty orders.
The list of Designated Persons (DPs) who are presumed to be in possession of UPSI must be maintained by the Compliance Officer, along with their immediate relatives and material financial relationships. The trading window closure regime under Regulation 4 restricts DPs from trading during specified periods. The dcomply Academy SEBI LODR + PIT Practitioner Certification walks the entire UPSI + SDD + trading-window compliance framework.