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Submission to SEBI on review of SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015

In September 2020, Securities and Exchange Board of India (SEBI) had recently released a consultation paper to solicit public comments on proposed amendments to the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. (LODR Regulations) The objective of the amendment is to strengthen corporate governance practices and disclosure requirements, ease compliance burden on listed entities, harmonize with the Companies Act, 2013 and maintain consistency within the LODR Regulations. Based on feedback from members, NASSCOM submitted its response to SEBI on the proposed amendments. Overall Comments We appreciate SEBI’s efforts to strengthen corporate governance practices and disclosure requirements, ease compliance burden on listed entities, and harmonize provisions under LODR Regulations with the Companies Act, 2013. While majority of the proposed amendments are beneficial in nature, the proposal on disclosure of financial results to stock exchange within 30 minutes of approval by the board may create unintended practical challenges and potentially disrupt established board processes. We have also requested SEBI to have a common unified filing portal (for both stock exchanges) where disclosure under particular requirement be made once and get disseminated to both the exchanges. Our detailed response to SEBI is attached for your reference.

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