Communication or procurement of unpublished price sensitive information.

(…)

(5) The board of directors shall ensure that a structured digital database is maintained containing the names of such persons or entities as the case may be with whom information is shared under this regulation along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Such databases shall be maintained with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database.

(6)- Not Present

Communication or procurement of unpublished price sensitive information.

(…)

(5) The board of directors or head(s) of the organisation of every person required to handle unpublished price sensitive information shall ensure that a structured digital database is maintained containing the nature of unpublished price sensitive information and the names of such persons who have shared the information and also the names of such persons with whom information is shared under this regulation along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available. Such database shall not be outsourced and shall be maintained internally with adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database.

(6) The board of directors or head(s) of the organisation of every person required to handle unpublished price sensitive information shall ensure that the structured digital database is preserved for a period of not less than eight years after completion of the relevant transactions and in the event of receipt of any information from the Board regarding any investigation or enforcement proceedings, the relevant information in the structured digital database shall be preserved till the completion of such proceedings.

With the present amendment, the following changes are introduced:

1. The requirement of maintaining structured digital database is now extended to other entities like Intermediaries or Fiduciaries with whom the Unpublished Price Sensitive Information is shared.

Now, all such Intermediaries or Fiduciaries are also required to maintain a structured digital database, in addition to the listed Company.

2. Under the new amendment, the structured digital database must also  include additional information i.e. the nature of unpublished price sensitive information and the names of such persons who have shared the information.

The structured digital database is now required to be maintained internally by the listed company/ intermediaries/ fiduciaries and same cannot be outsourced

With a newly inserted sub-clause (6), now the structured digital database has to be preserved for a period of minimum 8 years after completion of the relevant transactions. In case there is any investigation/enforcement proceedings, the relevant information must be preserved till the completion of such proceedings.

Previously, there was no requirement to preserve the records.

Disclosures by certain persons:

(…)

(2) Continual Disclosures.

(a) Every promoter, member of the promoter group,  designated person and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such other value as may be specified;

(b) Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information.

Explanation. — It is clarified for the avoidance of doubts that the disclosure of the incremental transactions after any disclosure under this sub-regulation, shall be made when the transactions effected after the prior disclosure cross the threshold specified in clause (a) of sub-regulation (2).

Disclosures by certain persons:

(…)

2) Continual Disclosures.

(a) Every promoter, member of the promoter group,  designated person and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such other value as may be specified;

(b) Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information.

Explanation. — It is clarified for the avoidance of doubts that the disclosure of the incremental transactions after any disclosure under this sub-regulation, shall be made when the transactions effected after the prior disclosure cross the threshold specified in clause (a) of sub-regulation (2).

(c) The above disclosures shall be made in such form and such manner as may be specified by the Board from time to time

Now, with the present Amendment,  such disclosure/s will have to be made in the form and manner which will be specified by SEBI.