Simplifying Transmission of Securities: SEBI Introduces a Harmonised, Risk-Based Framework under the LODR Regulations

The Securities and Exchange Board of India (SEBI) issued a consultation paper dated March 12, 2026 (Consultation Paper, which can be viewed by clicking on this link), proposing a revised framework for transmission of securities. Subsequently, at its 214th Board Meeting held on June 19, 2026 (Board Meeting, the press release for which can be viewed by clicking on this link), SEBI approved these proposals and on July 10, 2026, notified the SEBI (Listing Obligations and Disclosure Requirements) (Second Amendment) Regulations, 2026 (LODR Amendment, which can be viewed by clicking on this link), inter alia amending Regulation 40(7) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR Regulations). Pursuant to the LODR Amendment, SEBI also issued circular dated July 23, 2026 (Circular, which can be viewed by clicking on this link), operationalising the revised framework governing the transmission of securities.

The key changes introduced pursuant to the LODR Amendment, and the Circular are discussed below:

1. Amendments to the LODR Regulations 

The LODR Amendment introduces the following changes to the LODR Regulations:

• • Regulation 40(7) has been substituted to provide that a listed entity shall comply with all procedural requirements relating to transfer and transmission of securities as specified by SEBI from time to time, thereby shifting the regulatory framework from a schedule-based prescription to a circular-based regime.
  • Regulation 61(4), which requires a listed entity to comply with the procedural requirements relating to transfer and transmission of securities prescribed under Regulation 40, has been amended by substituting the words “specified in Schedule VII” with “as specified by the Board from time to time”.
  • Clause C of Schedule VII (which previously prescribed the procedural requirements for transmission of securities) has been omitted.

The LODR Amendment came into force on the date of its publication in the Official Gazette, i.e., July 10, 2026. The Circular, issued under Regulation 40(7), will come into force 30 days from the date of its issuance, i.e., on August 22, 2026.

2. Key Features of the Revised Transmission Framework

The Circular introduces a harmonised, standardised and risk-based process for transmission of listed securities and units issued by asset management companies (AMCs), consequent to the demise of the sole holder or all joint holders. The key features of the revised framework are as follows:

• • Quick Transmission Processing (QTP) Category: A new expedited processing category has been introduced for low-value transmission claims involving immediate relatives (i.e., parents, spouse, children and parents-in-law). The thresholds prescribed for the QTP category are as follows:

• • Enhanced Simplified Documentation Thresholds: The thresholds for availing the simplified documentation process (which prescribes reduced evidentiary requirements) have been enhanced as follows:

• • Documentation Simplifications: The revised framework also introduces several operational simplifications, including: (i) removal of the mandatory requirement of probate of a will (in line with recent amendments to succession laws); (ii) introduction of a combined affidavit-cum-no objection certificate (NOC) in place of separate affidavits and NOCs; (iii) acceptance of death certificates bearing a QR code as an eligible document; (iv) recognition of additional modes for verification of foreign death certificates through overseas branches of Indian banks or foreign banks having a correspondent banking relationship with Indian banks; and (v) removal of the requirement to furnish PAN for transmission of demat securities, since PAN details are already available with the depositories.

3. Exclusions and Time Limit for Settlement 

The revised framework applies to the transmission of listed securities and units issued by AMCs consequent to the demise of the sole holder or all joint holders. However, it does not apply in cases involving disputes or competing claims in respect of the securities sought to be transmitted. Further, the processing entities (listed companies / registrar and transfer agents / depositories / depository participants / AMCs) are required to process the transmission within a period not exceeding 21 calendar days or any such period as may be specified by the Board, from the date of receipt of all the required documents associated with the claim.

Overall, the revised transmission framework represents a significant step towards enhancing ease of doing investment by reducing procedural complexity, standardising documentation requirements across intermediaries, and introducing a calibrated, risk-based framework under which the applicable documentation requirements vary depending upon the value of the transmission claim.