Do we need to record the entry in the Structured Digital Database as soon as it is shared, or as soon as possible? How much grace time do we have?
The sharing can be recorded subsequently, but the gap should be as short as possible. Even where the time elapsed goes beyond a feasible period, the entry must still be made, since delayed compliance is better than non-compliance.
The general view in practice is that the entry should be made as soon as possible and, in any event, within 24 hours of the information being shared. Exceptions can arise where making the entry at once would itself create a negative consequence in the interim, but those are exceptions and they need to be capable of explanation afterwards.
Timing matters because the entry is the evidence. An entry made days later, from memory, cannot show when the information arose, in what order it reached each recipient, or whether anyone traded in the interval. A same-day entry can, and that is what an inspection turns on.
Email automation in Affinisio(SDD) structured digital database software records the entry at the moment the email is sent, so the gap stops being a matter of individual discipline. Where automation is not in use, the quick click and ready access on Affinisio(SDD) structured digital database for SEBI PIT compliance makes it a quick ‘in-record-out’ action, and an entry can be made over a cellphone where the organisation grants access to internal servers.
Two adjacent questions are answered separately. On whether the entry has to be made before the information is shared, see whether UPSI flow must be pre-entered in the SDD. On whether the emails themselves can be held in the database, see whether emails can be stored in the Structured Digital Database as they are. For what counts as unpublished price sensitive information in the first place, see the guide to UPSI.
