BSE Guidance on Record Date Disclosures for Corporate Actions under SEBI LODR
The Bombay Stock Exchange, through Notice No. 20260824-16 dated 24 August 2026, has issued a detailed set of Frequently Asked Questions (FAQs) to streamline and standardise how listed entities intimate Record Dates for various corporate actions. These FAQs are intended to ensure compliance with Regulation 42 and Regulation 60(2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (“SEBI (LODR) Regulations, 2015”).
This article reworks and explains those FAQs in a structured, user-friendly format for compliance officers, company secretaries and finance/legal teams of listed entities.
1. Scope and Applicability of Record Date for Corporate Actions
1.1 Who can fix a Record Date?
- All listed entities are permitted to fix a Record Date for corporate actions that fall within the scope of
Regulation 42(1)of theSEBI (LODR) Regulations, 2015. - This applies to equity-listed entities and, where applicable, to entities with listed debt instruments.
1.2 Special requirement for InvITs and REITs
For InvITs and REITs, the FAQs reiterate that:
- The Record Date must be disclosed in accordance with the applicable SEBI regulations governing InvITs/REITs.
- The disclosure must be made at least two working days before the Record Date.
- While counting this period, both the date of intimation and the Record Date itself are excluded.
2. Mandatory Filing Path on BSE Listing Centre
A key compliance aspect highlighted by BSE is the exact route through which Record Date intimations must be filed on the BSE Listing Centre. Use of any alternative route will result in the submission not being taken on record.
2.1 For equity-listed scrips – Regulation 42
For corporate actions under Regulation 42 related to equity-listed securities, the correct path on the BSE Listing Centre is:
Listing Centre → Listing COMPLIANCE → Corporate Announcements → Corporate Actions → Submission
This path must be used for:
- Original Record Date intimation, and
- Any revision or cancellation of the Record Date related to equity-listed scrips.
2.2 For debt-listed scrips – Regulation 60(2)
For debt-listed securities where Regulation 60(2) applies, the filing path is distinct:
Listing Centre → Listing COMPLIANCE → Corporate Announcements → Compliances → Reg 60(2) → Submission
BSE has categorically stated that:
- Any submission routed through any other segment or menu option will not be accepted or treated as a valid filing.
3. Record Date vs Cut-off Date and Book Closure: Terminology and Validity
3.1 Is Cut-off date or Book Closure date required?
The FAQs clarify that:
- After the relevant amendments, BSE will recognise only the “Record Date” in relation to corporate actions.
- A Cut-off date or Book Closure date, even if specified by the company, will not be recognised by the Exchange for compliance with
Regulation 42.
3.2 Incorrect usage and non-compliance risks
BSE has emphasised certain common errors that will amount to non-compliance:
- Merely selecting the “Record Date” option (radio button) in the announcement tab without clearly mentioning the term “Record Date” in the text of the intimation will not suffice.
- Uploading a PDF that fails to explicitly use the term “Record Date” will also be treated as non-compliance with
Regulation 42of theSEBI (LODR) Regulations, 2015. - Any reference to “cut-off date” or “book closure date” instead of “Record Date” will not be recognised as a proper Record Date intimation.
Important: Submissions that do not clearly specify “Record Date” as such may not be taken on record by BSE, and applicable fines may be imposed under the Exchange’s enforcement framework.