In the dynamic landscape of securities law, the SEBI Insider Trading Compliance Timeline charts a decade-long transformation. SEBI’s approach to insider trading has evolved from basic policy to an intricate compliance regime centred around the Structured Digital Database (SDD). For listed companies, this is no longer just a formality—it’s a critical legal obligation. Digitizing your UPSI records is now a compliance imperative, with non-compliance risking penalties, personal liability, and reputational harm.
Foundation of the SEBI Insider Trading Compliance Timeline
PIT Regulations 2015: The First Compliance Framework
Date: December 31, 2015
Impact: SEBI (Prohibition of Insider Trading) Regulations, introduced the Prohibition of Insider Trading (PIT) Regulations, requiring all listed entities to control and monitor UPSI dissemination.
While SDD was not mandatory at this stage, the idea of tracking UPSI was officially introduced—setting the stage for structured digital compliance.
SEBI Insider Trading Compliance Timeline Evolution
December 31, 2018 → SDD Introduced in Law
| SEBI issued the Prohibition of Insider Trading (Amendment) Regulations, 2018, mandating the creation of a Structured Digital Database (SDD). Effective From: April 1, 2019 |
| Key Regulation: “Such database shall be maintained with time stamping and audit trails to ensure non-tampering…” |
Takeaway: SDD became mandatory. All UPSI sharing must now be recorded digitally, time-stamped, and secured.
July 25, 2019 → Trading Window & UPSI Handling Clarified
| SEBI released the Second Amendment to PIT Regulations to refine procedures around UPSI and trading windows. |
Takeaway: Tracking “who knew what and when” became critical—further reinforcing the role of SDD.
July 17, 2020 → SDD Control, Retention Period Introduced
| Amended Regulation 3(5): “The database shall not be outsourced… must be maintained internally.” |
| Regulation 3(6): “Preserve for a period of not less than eight years.” |
Takeaway: SDD must be in-house, tamper-proof, and retained for 8 years. No third-party outsourcing allowed.
October 28, 2022 → NSE SOP on Audit Trails & Role Controls
| NSE Issued a Standard Operating Procedure (SOP) emphasizing: 🔸Role-based access 🔸User-wise audit trails 🔸IP-level tracking |
Takeaway: SDD must be in-house, tamper-proof, and retained for 8 years. No third-party outsourcing allowed.
November 24, 2022 → Legal Reinforcement of UPSI Definition
| SEBI updated the definition of UPSI, indirectly impacting SDD by expanding the type of events that must be tracked. |
Takeaway: More events fall under UPSI. Your SDD must capture a wider range of internal developments.
January 25, 2023 → NSE SOP for Digital Controls
| NSE emphasized automation and integration for SDD tools that required alignment with: 🔸Email systems 🔸Document sharing platforms 🔸Role-based control features |
Takeaway: Automation is no longer optional. SDD must be tech-integrated and real-time.
March 12, 2025 → UPSI Definition Expanded by Third Amendment
| SEBI formally expanded UPSI categories under Regulation 2(1)(n) of PIT guidelines. New inclusions: 🔸Credit rating changes 🔸IBC proceedings 🔸Forensic audits 🔸Regulatory actions abroad 🔸Defaults and major agreements |
Takeaway: Your SDD must now track UPSI across broader corporate and legal activities, including third-party disclosures.
The Real Risks of Non-Compliance
If you’re still relying on:
- Manual registers
- Spreadsheets
- Email inboxes
- …your company is non-compliant under SEBI regulations.
Penalties under Section 15G of the SEBI Act include:
- ₹10 lakh minimum fine
- Up to ₹25 crore or 3x the profit gained, whichever is higher
- Personal liability for compliance officers
…your company is non-compliant under SEBI regulations.
SEBI Insider Trading Compliance Timeline: What It Means for You
- The timeline shows a steady move from principles to enforcement.
- SDD is non-negotiable: it’s the single source of truth in any insider trading investigation.
- Updates are frequent and often technical — companies must stay alert and adapt quickly.
Best Practices to Stay Compliant with SEBI Insider Trading Rules
To effectively comply with the SEBI Insider Trading Compliance Timeline, companies should:
- Adopt tamper-proof, cloud-based SDD platforms
- Assign clear UPSI handling roles
- Train staff on SDD protocols
- Integrate SDD with enterprise systems
- Conduct quarterly internal audits
- Engage external experts for gap analysis
Strengthening SEBI Insider Trading Governance through Digital Compliance Tools Like InSiDDer SDD
Your SEBI-Compliant SDD Tool: InSiDDer
InSiDDer Capabilities:
- Logs every UPSI sharing event
- Maintains audit-ready trails
- Supports IP-based and role-based controls
- Integrates with existing IT systems
The SEBI Insider Trading Compliance Timeline reflects a regulatory environment that’s become digitally rigorous. From conceptual beginnings in 2015 to detailed, tech-integrated expectations by 2025, the evolution is unmistakable.
Companies must respond not just with policy—but with technology, training, and automation. The next SEBI inspection may not ask if you have SDD, but how good your system really is.