Reg 21 risk management committee cadence
At least two risk management committee meetings a financial year, with no more than 210 days between two consecutive meetings.
At least 2 a financial year, maximum 210-day gap
- SEBI
- SEBI events and governance
- Not specified
- 2026-09-01
Two meetings a financial year at minimum, and no more than 210 days between two consecutive meetings. The gap is 210 days, not 180: it was substituted with effect from 17 May 2024. The committee is required of the top 1000 listed entities and of a high value debt listed entity.
The gap between two consecutive meetings is 210 days, substituted from 180 days with effect from 17 May 2024. The two-meeting minimum did not change. This is the figure most commonly quoted wrongly for this committee, and it errs in the strict direction, so a stale checklist flags a breach that is not one.
Deadlines counted from an event
The risk management committee must meet at least twice in a financial year, with a maximum gap of 210 days between any two consecutive meetings, under Reg 21(3A) and Reg 21(3C). The gap was substituted from 180 days with effect from 17 May 2024, and the word financial was inserted with effect from 13 December 2024.
The rule
The risk management committee must meet at least twice in a financial year, with a maximum gap of 210 days between any two consecutive meetings, under Reg 21(3A) and Reg 21(3C). The gap was substituted from 180 days with effect from 17 May 2024, and the word financial was inserted with effect from 13 December 2024.
Who must comply
- The top 1000 listed entities by market capitalisation, under Reg 21(5)
- A high value debt listed entity, under Reg 21(5)
- An entity outside the top 1000 by market capitalisation, and which is not a high value debt listed entity, does not have to constitute the committee.
- Reg 15(2) exempts an entity with paid-up equity share capital of ₹10 crore or less and net worth of ₹25 crore or less, and an entity listed on the SME Exchange, from Reg 17 to Reg 27.
Statutory basis
Before you file
- Confirm whether the entity is inside the top 1000 by market capitalisation, or is a high value debt listed entity.
- Fix at least two committee meeting dates in the financial year.
- Check that no two consecutive meeting dates are more than 210 days apart.
- Prepare the risk management policy and the cyber security review for the agenda.
How to file
- Hold at least two risk management committee meetings in the financial year.
- Keep the gap between two consecutive meetings at 210 days or less.
- Review the risk management policy and the risk register at those meetings.
- Report the meeting count and dates in the quarterly governance filing.
No separate filing. Reported through the quarterly governance report to the exchanges
If you miss it
No per-day exchange fine is asserted here, because this provision is not on the fine table we have verified. A breach of a corporate-governance condition is a breach of listing conditions, which section 23E of the Securities Contracts (Regulation) Act reaches at not less than ₹5 lakh and up to ₹25 crore. SEBI's other head is section 15HB of the SEBI Act, the residual penalty that applies where the Act provides no specific penalty for the contravention. Section 15A(b) is not the right head, because a missed meeting is not a failure to furnish information.
- The default shows in the quarterly governance report inside Integrated Filing (Governance), so it becomes visible to the exchange and to investors without any separate complaint
- SEBI has moved to a settlement route for many governance defaults, which still carries a settlement amount and an admission on the record
Recent changes affecting this
Relaxation from SEBI Master Circular for Minimum Public Shareholding Non-Compliance
Master Circular for compliance with the provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 by listed entities
Master Circular for listing obligations and disclosure requirements for Non-convertible Securities, Securitized Debt Instruments and/ or Commercial Paper
Common questions
Is the maximum gap 180 days?
Not since 17 May 2024. It is 210 days. A checklist still showing 180 days is applying a superseded figure and will call a compliant gap a breach.
Which entities have to constitute this committee?
The top 1000 listed entities by market capitalisation, and a high value debt listed entity, under Reg 21(5). A debt-only listed entity has a parallel two-meeting cadence at Reg 62I in Chapter VA.