NSE Clarifies Record Date Filing Requirements for Corporate Actions Under SEBI (LODR) Regulations, 2015

The National Stock Exchange of India (NSE) has released a detailed set of Frequently Asked Questions addressing the procedural and compliance requirements for filing Corporate Actions under Regulation 42 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. These FAQs serve as an important reference point for listed entities, InvITs, and REITs seeking clarity on how Record Dates must be fixed, disclosed, revised, or cancelled on the NEAPS platform.

Below is a structured walkthrough of all ten questions covered in the NSE's FAQ document, with commentary on key compliance obligations.

Who Can Fix a Record Date for Corporate Actions?

Eligibility of Listed Entities

Under Regulation 42 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, every listed entity is entitled to fix a Record Date in connection with a Corporate Action. This applies broadly across all categories of listed companies.

For InvITs and REITs, the disclosure obligation is slightly different. These entities are governed by their respective SEBI Regulations and are required to disclose the Record Date at least two working days in advance, with the count excluding both the date of intimation and the Record Date itself.

Key Takeaway: While all listed entities can fix a Record Date, InvITs and REITs face a distinct advance disclosure requirement under their applicable SEBI frameworks.

Where Must the Record Date Intimation Be Filed?

Mandatory Use of the NEAPS Platform

NSE has made it unambiguously clear that the intimation of a Record Date must be submitted exclusively through the NEAPS platform using the following prescribed navigation path:

NEAPS > COMPLIANCE > Announcements > Corporate Action > Submission

⚠️ Critical Compliance Note: Any submission made through a path other than the one specified above will not be taken on record by the Exchange. Listed entities must strictly adhere to this filing route to ensure valid compliance.

This requirement removes any ambiguity about alternate filing channels and places full responsibility on the listed entity to use the correct system path.

Is a Cut-Off Date or Book Closure Date Acceptable?

Only the Record Date Is Recognised

Following the recent amendments, the Exchange has categorically stated that only the Record Date will be recognised for any Corporate Action. Neither a Cut-Off Date nor a Book Closure Date will be accepted as a substitute.

Listed companies must note the following:

  • Selecting only the 'Record Date' radio button in the announcement tab — without expressly stating 'Record Date' in the submission — does not constitute valid compliance with Regulation 42 of the SEBI (LODR) Regulations, 2015.
  • Uploading a PDF that makes reference to a 'cut-off date' or 'book closure date' in place of the term 'Record Date' will not be recognised.
  • Submissions of this nature will be rejected and may attract applicable fines.