On 5^th July 2025 SEBI has introduced a special window from July 07, 2025 to January 06, 2026 for re-lodgement of physical share transfer requests. This initiative allows investors a final chance to regularize transfer deeds lodged before April 01, 2019 but rejected or left unprocessed due to documentation deficiencies.

SEBI’s Rationale Behind the Initiative

As part of its continued efforts to digitize securities transactions and enhance investor convenience, SEBI had discontinued the transfer of securities in physical mode effective April 01, 2019. To accommodate pending cases, a re-lodgement window was earlier allowed until March 31, 2021 for transfer requests that had been rejected or returned due to documentation deficiencies.

However, SEBI subsequently received numerous representations from investors, Registrars and Transfer Agents (RTAs), and listed companies stating that several investors were unable to meet this deadline. After due consultation with a panel comprising RTAs, listed companies, and legal experts, SEBI has now introduced a special six-month window to provide these investors with a final opportunity to regularize their share transfers.

Applicability – This special window applies to:

• Investors holding physical shares, whose transfer requests were lodged on or before March 31, 2019, and
• Whose transfer applications were rejected/returned or left unprocessed due to:
  • Incomplete documentation,
  • Deficient processes, or
  • Any other valid reason.

This window does not permit fresh transfers of physical shares; it is strictly for re-lodgement of old cases.

Key Compliance Requirements Under the Special Window

• All securities re-lodged under this window must be transferred only in dematerialised (demat) form.
• Listed companies and RTAs must strictly follow the transfer-cum-demat process as per SEBI guidelines.
• Pending transfer requests, which are currently unprocessed with listed companies or RTAs, are also eligible under this window.
• Listed companies, RTAs, and stock exchanges must publicize the special window through print and social media. Awareness campaigns are to be conducted bi-monthly throughout the six-month period.
• Listed companies and RTAs are required to submit monthly reports to SEBI in the prescribed format (Annexure-A). These reports must detail the publicity measures undertaken and the status of shares re-lodged and dematerialised under the special window scheme.
• Companies and RTAs must update their internal SOPs and communication protocols to align with SEBI’s directives. They must also ensure timely identification and processing of all eligible transfer requests submitted during the special window period.

Conclusion

SEBI’s initiative to open a special window for the re-lodgement of physical share transfers is a thoughtful and timely measure that balances regulatory rigor with investor compassion. It not only addresses long-pending grievances of investors but also aligns with SEBI’s broader vision of a fully digitized and transparent securities market. By ensuring one final opportunity to regularize old cases, this move protects investor rights while encouraging timely compliance.

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CS Isha Deshwal