Revamped Regulatory Guidance: SEBI Notifies Informal Guidance Scheme 2025

The Securities and Exchange Board of India (SEBI) has notified the SEBI (Informal Guidance) Scheme, 2025 (New Scheme, which can be viewed by clicking on this link) vide a notification dated November 18, 2025. The New Scheme, which came into effect on December 1, 2025, replaces the SEBI (Informal Guidance) Scheme, 2003 (Old Scheme).

While the fundamental mechanism of providing “No-action letters” and “Interpretive letters” remains unchanged, the New Scheme introduces structural reforms to professionalize the process and expand access. 

• Key Changes 

The New Scheme introduces significant modifications to eligibility and procedure:

1. 1. Expanded Eligibility Criteria: The New Scheme broadens the scope of eligible applicants beyond listed companies and intermediaries. It now explicitly includes any person or entity appointed to manage investments of pooled investment vehicles (covering AIFs, REITs, and InvITs) or their trustees. Additionally, it now covers Market Infrastructure Institutions (MIIs) like recognized stock exchanges, clearing corporations, and depositories.

1. 2. Centralized Filing via Nodal Cell: Unlike the Old Scheme where applications were addressed generally to the “concerned Department”, the New Scheme mandates that all applications be filed electronically via email to a centralized Nodal Coordination Cell. The application must strictly adhere to the format stipulated in Schedule-I.

1. 3. Revised Fee Structure: To discourage non-serious applications, the application fee has been increased to INR 50,000. Additionally, the New Scheme codifies a processing deduction of INR 10,000 if an application is rejected, ensuring administrative costs are covered.

1. 4. Structured Timelines: To ensure efficiency, the New Scheme mandates that if SEBI seeks clarifications, the applicant must respond within 15 days (extendable once by another 15 days). Crucially, the time taken by the applicant to respond is now explicitly excluded from SEBI’s internal 60-day timeline for disposing of the application.

• Comparison: The 2003 vs. 2025 Scheme

To aid stakeholders in navigating the transition, the table below delineates the critical procedural and substantive differences between the Old Scheme and the New Scheme:

 The New Scheme reflects SEBI’s intent to streamline the informal guidance process by enforcing stricter timelines and mandating digital submissions to a centralized Nodal Coordination Cell. The broad inclusion of pooled investment vehicle managers fills a critical regulatory gap. Simultaneously, the enhanced fee structure and structured timelines are likely to improve the efficiency of SEBI’s disposal process.