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Articles, posts, insights, opinions, factoids or musings with SDD FAQs
The entry may be made after the sharing, but the gap should be as short as possible. Practice is same day and in any event within 24 hours, because the entry is the evidence of when the information arose and who received it.
Yes. The company stays listed, so the obligation follows the listing. Insolvency events are named in the amended UPSI list, and the resolution process moves price sensitive information to creditors, resolution applicants and their advisers.
Yes. A debt-listed issuer is a listed entity because it has issued securities that are listed. Trading window closure and the structured digital database are independent obligations, so relief from one does not touch the other.
Yes, with a condition. The software may come from a vendor, but it must be installed on a server the company owns or in its own cloud tenancy. A vendor-hosted, login-based database is contrary to Regulation 3(5).
Do unlisted intermediaries and fiduciaries also face the requirement to maintain the SDD?
The SDD captures the nature of UPSI and the details of its sharing, not the information itself. Holding the actual content raises the very risk the database exists to reduce.
Does a listed entity need to maintain a Structured Digital Database and provide the compliance certificate for the quarter even if it has no UPSI? Since every listed company would need to, at the very minimum, have at least one event every quarter that would qualify as a UPSI related event, being the quarterly financials,…
Which entities are required to submit the SDD compliance certificate? Who provides the compliance certificate for SDD from the entity? Currently, listed entities are required to submit the SDD compliance certificate. In the future, key intermediaries (for example, those having a merchant banking license) may ultimately also be asked to provide the compliance certificate as…
What should be recorded in the Structured Digital Database from items covered under regulation 30 or regulation 51 ? Are these to be considered UPSI as well? These regulations read together with the Schedule III of SEBI LODR incorporate items that are deemed material as also those that are material based on the pre-determined thresholds.…
What are the regulatory non-compliances related to maintenance of the Structured Digital Database? What are the non-compliance consequences?
Who is responsible to ensure maintenance of SDD and prevent failure of entries?
The rationale is control over external sharing, but the trail splits internally first. SEBI’s Comprehensive FAQs require SDD entries whether the information moves inside or outside the company.
The word audit trail is used often in relation to the Structured Digital Database. What does it mean?
Does each company in a group of companies need to maintain a Structured Digital Database separately?
Does the unlisted subsidiary of a listed company which is sharing information on the former need to maintain a Structured Digital Database?
Does the Structured Digital Database need to capture information in relation to my listed entity only or should it also include my listed subsidiary? What if the subsidiary is unlisted?
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