Insider Designated Database; SEBI PIT Compliance for Designated Persons

Affinisio(IDD) — Insider Designated Database — is a key module of the Affinisio suite by Affinisio Technologies LLP. It maintains the database of designated persons required under the SEBI (Prohibition of Insider Trading) Regulations, 2015 in India — a centralised, continuously updated register of every designated person and their mandated details, including PAN, immediate relatives, persons with a material financial relationship, educational and employment history, and contact information. Affinisio(IDD) automates the full lifecycle — onboarding, annual affirmations, mass designation and offboarding — through a secure, self-service portal, and its records feed directly into Affinisio(ETT) and Affinisio(SDD) for unified insider-trading compliance. Affinisio(IDD) is fully certified for regulatory compliance and is used by a large number of listed entities, conglomerates, financial institutions, intermediaries and fiduciaries.

A designated person is anyone the board, in consultation with the compliance officer, brings within the organisation’s code of conduct under Regulation 9 of the SEBI (Prohibition of Insider Trading) Regulations, 2015 — based on their role, function and access to unpublished price-sensitive information (UPSI). This typically includes directors, key managerial personnel, senior management and persons up to two levels below the CEO, employees in finance, legal, secretarial, strategy and deal teams, promoters, and staff of material subsidiaries — as well as employees of intermediaries and fiduciaries who handle UPSI. Every listed company, intermediary and fiduciary must maintain an up-to-date database of its designated persons and their mandated details, under Schedule B for listed entities and Schedule C for intermediaries and fiduciaries. Affinisio(IDD) maintains this register for all of these segments, with dedicated variants for listed entities, intermediaries or fiduciaries and mutual funds, and significant value-add features that track designation history and ensure sanity-tested and complete declarative compliances.

For each designated person, the database must hold their name, PAN or other legally authorised identifier, designation, department and date of designation; their contact details and phone numbers; the names and PANs of their immediate relatives; and the names and PANs of any person with whom they share a material financial relationship. A material financial relationship or MFR is defined as a relationship in which the designated person has received, in the preceding twelve months, a payment such as a loan or gift equal to at least 25% of the payer’s annual income, excluding arm’s-length transactions. Educational institutions and past employers are captured as one-time disclosures and are pre-filled for follow-on confirmations. Affinisio(IDD) collects and keeps all of this current through a secure, automated, self-service portal, with automated annual and event-based affirmations — so each designated person maintains and affirms their own immediate-relative and MFR details while the compliance officer retains a complete, validated and audit-ready record.

They serve different purposes under the SEBI PIT Regulations and are often confused. The Insider Designated Database (IDD) is the register of who the insiders are — every designated person and their mandated details — maintained under the Code of Conduct in Regulation 9. The Structured Digital Database (SDD) is the event log of unpublished price-sensitive information sharing — who shared what UPSI, with whom, and when — maintained under Regulation 3(5). In short, IDD answers “who is an insider and what are their details,” while SDD answers “when and to whom was UPSI communicated.” Affinisio(IDD) focusses on Designated Persons and the maintenance of a database of Insiders. Affinisio(SDD) is only tangentially connected to Designated Persons but is, in theory, applicable to all, which is why there is significant involvement for external entities and persons as well. Affinisio offers both as distinct, dedicated modules — Affinisio(IDD) and Affinisio(SDD) — that integrate seamlessly with each other and with Affinisio(ETT), so an organisation can run its complete SEBI PIT compliance from one connected suite or adopt each module on its own.

Yes. Affinisio(IDD) is available for on-premises deployment as well as privately controlled cloud under the user’s administration, so the highly sensitive personal data it holds — PANs, immediate-relative details and material financial relationships of designated persons — stays on infrastructure the organisation controls, and Affinisio never has access to it. Access is governed by granular, role-based controls on a strict need-to-know basis, with a complete audit trail of every change, giving the board and compliance officer full ownership and control of designated-person data while meeting strict data-residency and privacy requirements.

A designated-persons database must be kept continuously up to date — through initial capture at onboarding, annual affirmations, and event-based updates whenever a person joins, is promoted, transfers, changes role or exits, and whenever their relatives or material financial relationships change. For designated persons who have resigned, SEBI also requires that his or her contact details be maintained for at least one year after resignation and their data preserved for five years. Affinisio(IDD) automates this entire lifecycle: its “trigger-and-forget” workflows intimate, guide and remind each designated person to submit and affirm their details; mass designation assigns and updates large numbers of persons in one action; and DP timeline reporting tracks every designation, status change and exit — while retaining post-separation records for the mandated periods, giving the compliance officer an always-current, audit-ready register.