Reg 31(1)(a) shareholding pattern before listing
Filing the shareholding pattern with the exchange one day before the securities are listed.
1 day before listing
Counted from the date of listing of the securities, counted backwards
- SEBI
- SEBI events and governance
- Not specified
- 2026-09-01
One day prior to the listing of the securities. This is a one-off filing tied to the listing date and is separate from the quarterly shareholding pattern under Reg 31(1)(b), which is due within 21 days of the quarter end.
Deadlines counted from an event
One day prior to the listing of the entity's securities on the stock exchange, submit the shareholding pattern to the exchange. Reg 31(1)(a) covers this pre-listing filing; the recurring quarterly filing is Reg 31(1)(b).
The rule
One day prior to the listing of the entity's securities on the stock exchange, submit the shareholding pattern to the exchange. Reg 31(1)(a) covers this pre-listing filing; the recurring quarterly filing is Reg 31(1)(b).
Who must comply
- An entity whose specified securities are being listed on a recognised stock exchange
Statutory basis
Before you file
- Get the final allotment and shareholding data from the registrar and transfer agent.
- Confirm the listing date with the exchange.
- Prepare the shareholding pattern in the format the exchange specifies.
How to file
- Prepare the shareholding pattern as at the day before listing.
- Submit it to the exchange one day before the listing date.
- Start the quarterly Reg 31(1)(b) cycle from the first quarter after listing.
Stock exchange electronic filing system
If you miss it
No per-day exchange fine is asserted here, because this provision is not on the fine table we have verified. SEBI adjudicates a late or missed disclosure under section 15A(b) of the SEBI Act, which reaches ₹1 lakh for each day the failure continues and is capped at ₹1 crore. Section 23E of the Securities Contracts (Regulation) Act is the other head, at not less than ₹5 lakh and up to ₹25 crore for a breach of listing conditions. Orders in this area normally land in lakhs rather than near the ceiling.
- The exchange records the default in the entity's compliance history, and a repeated default feeds SEBI's decision to adjudicate
- The disclosure still has to be made after the deadline passes, and it has to carry an explanation for the delay
- Disclosing favourable events on time while letting unfavourable ones slip is charged as a breach of Reg 4(1)(d) in its own right, alongside the specific provision
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 this the same as the quarterly shareholding pattern?
No. Reg 31(1)(a) is a one-off filing one day before listing. The quarterly filing is Reg 31(1)(b), due within 21 days of the quarter end, and it belongs with the periodic filings.