Temporary Relaxation Aims to Resolve Legacy Share Issues While Reinforcing Dematerialisation Goals
SEBI’s Push to Resolve Legacy Share Transfer Issues
In a significant move to address long-standing investor grievances, SEBI has proposed measures to ease the transfer and dematerialisation of old physical shares. These changes are specifically aimed at investors who lodged transfer requests prior to April 1, 2019.
- Many of these investors missed earlier re-lodgement windows due to valid issues like deceased sellers, dissolved companies, or incorrect submissions.
- SEBI’s proposal targets making the process smoother while ensuring continued focus on dematerialisation as the long-term objective.
Temporary Relaxation with a Sunset Clause
SEBI’s consultation paper proposes a time-bound exception to current rules, allowing the transfer of physical shares lodged before the cutoff date, even if not yet dematerialised.
- This exception would be governed by a sunset clause, ensuring it’s a one-time opportunity and doesn’t derail long-term market digitisation efforts.
- Verified shares will be directly credited to the investor’s demat account once authenticated by the company or Registrar and Transfer Agent (RTA).
Eliminating the ‘Letter of Confirmation’ (LOC)
One of the most cumbersome steps for investors has been the requirement to obtain and submit a Letter of Confirmation (LOC) within 120 days of a service request.
- If this timeline is missed, the shares are moved to a Suspense Escrow Demat Account (SEDA), complicating retrieval.
- SEBI now proposes abolishing the LOC process entirely to streamline dematerialisation and reduce administrative hurdles.
Simplified Process for Demat Credit
Under the new framework, investors will only need to provide their Client Master List (CML) to initiate the dematerialisation or transfer request.
- Once due diligence is completed, RTAs and listed companies will credit shares directly to demat accounts—eliminating intermediary steps.
- This aims to reduce delays, cut paperwork, and ensure rightful owners can access their assets with fewer friction points.
Reopening of Transfer Window for Old Shares
To further assist impacted investors, SEBI has announced a special window from July 7, 2025, to January 6, 2026, for re-lodging physical share transfer requests that were earlier rejected or missed.
- This window is expected to bring relief to many who had missed earlier deadlines.
- SEBI has proposed amendments to Regulation 40(1) of LODR Regulations to legally facilitate this move.
Balancing Convenience with Compliance
SEBI made it clear that while these proposals offer relief, they are not a step back from the broader dematerialisation mandate.
- The temporary relief ensures fair access to rightful ownership, especially in legacy cases.
- But the sunset clause and regulatory amendments underline SEBI’s continued push toward a fully digital securities market.