When SEBI and RBI paths meet…
SEBI asks Banks to maintain two separate SDD (Structured Digital Databases), continuing its enhanced focus on ‘Prohibition of Insider Trading’ regulations.
A Mint article by Neha Joshi outlines the unenviable “square peg in a round hole” situation faced by banks’ technology systems, highlighted by Nishant Shah, CEO – a key example of the interplay between the Reserve Bank regulations on IT infrastructure and the SEBI regulations on Insider Trading.
The article highlights several key facts and challenges with the dual SDD need highlighted by SEBI and how applications such as Affinisio(SDD) structured digital database software are amongst the few sophisticated offerings that provide barriered access to manage UPSI tracking for ‘home’ and ‘other’ entities all within a single environment.
Background to the Article: Dual SDD for Banks
On 3 September 2025, the SEBI Chairman addressed the MDs and CEOs of listed banks on strengthening compliance with the insider trading regulations. He said that for listed banks this means maintaining two sets of structured digital databases (SDDs): one for the bank’s own internal unpublished price-sensitive information (UPSI), and another for UPSI it holds in a fiduciary capacity for other listed companies.
The address also said that UPSI must always be handled on a need-to-know basis, that SEBI requires all sharing of UPSI to be recorded in a secure, time-stamped and tamper-proof system, and that strict access protocols, information walls and secure digital systems are essential.
Where the Two Sets Come From
Regulation 3(5) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 requires the board of directors or head of every person required to handle UPSI to ensure that a structured digital database is maintained internally, with controls such as time stamping and audit trails. Fiduciaries such as consultants, auditors and merchant bankers are also covered. The Chairman’s address applied this to listed banks as two sets of SDDs:
- For the bank’s own UPSI, as a listed company.
- For UPSI held in a fiduciary capacity for other listed companies.
Affinisio(SDD) PRO Series: Built for Listed Intermediaries
The Affinisio(SDD) PRO Series is built precisely for such instances and is the variant for SEBI-regulated intermediaries that are listed and for mutual funds, and it manages the UPSI of your own entity and of other listed and to-be-listed entities in one system, with barriered access between them:
- Own and other entities in one system: UPSI of your own entity and of other listed and to-be-listed entities, with an extensive pre-loaded database of listed entities.
- Barriers inside the institution: intra-entity visibility barriers, and information barriers by deal team and by project.
- Need-to-know access: project-based management of UPSI events, with project access restricted on a strict need-to-know basis.
- Organisation: functional groups to organise people by department, function or team, and scalable organisational units for group structures.
- Inspection-ready records: certified for regulatory compliance, with immutable and detailed audit trails and time stamping, and custom regulatory reports ready for SEBI inspection.
- Email integration: zero-touch email integration logs UPSI communications automatically and securely, with automated alerts for unrecognised senders or receivers.
Affinisio(SDD) remains fully certified for regulatory compliance. More on the Affinisio(SDD) variants and features page.
Read the full article below –
Sebi’s new rule to curb insider trading conflicts with bank secrecy law, experts argue
