Five-year retention of insider trading disclosures
The company's duty to keep every disclosure it receives under PIT Chapter III for five years, in physical or electronic form.
Standing duty, no filing date
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
There is no due date. PIT Reg 6(4) requires the company to keep every disclosure made to it under Chapter III for five years, in the prescribed format, either physically or electronically. This is the real obligation in Reg 6: the regulation imposes no filing of its own, only the general provisions on form and content and this retention duty.
Reg 6 is widely described as carrying initial and annual disclosures by promoters, directors and key managerial personnel. It carries neither. The disclosures are in Reg 7, there is no annual one, and what Reg 6 actually adds is the five-year retention duty on this page.
Deadlines counted from an event
Keep every disclosure made to the company under Chapter III for five years. Reg 6(4) allows physical or electronic form, and paragraph 4.1.1 of the Master Circular on Surveillance of Securities Market sets the format. The five years run from the disclosure, so the retention set changes continuously rather than on a filing date.
The rule
Keep every disclosure made to the company under Chapter III for five years. Reg 6(4) allows physical or electronic form, and paragraph 4.1.1 of the Master Circular on Surveillance of Securities Market sets the format. The five years run from the disclosure, so the retention set changes continuously rather than on a filing date.
Who must comply
- Every listed company that receives a disclosure under PIT Chapter III
- The compliance officer, who holds the records in practice
Statutory basis
- PIT Reg 6(4), preservation of Chapter III disclosures for five years, and Reg 6(1) to 6(3), general provisions
- PIT Regulations, 2015, consolidated text as amended to 12 March 2025 (PDF)
- Master Circular on Surveillance of Securities Market, paragraph 4.1.1, format and manner of maintaining the disclosures
Before you file
- Set up one register or folder for Chapter III disclosures.
- Use the format that paragraph 4.1.1 of the Master Circular prescribes.
- Decide whether the records are kept physically or electronically.
How to file
- File each disclosure as it is received.
- Record the date of receipt on the disclosure.
- Keep every disclosure for five years from the date it was made.
- Do not file the register with SEBI or an exchange. Produce it on demand.
If you miss it
Section 15A(c) of the SEBI Act covers this directly: a person required by the regulations to maintain books of account or records who fails to do so is liable to ₹1 lakh for each day the failure continues, capped at ₹1 crore. Section 15HB is the fallback at up to ₹1 crore. There is no exchange fine, because the register is not a filing.
- Missing records leave the company unable to show that its designated persons disclosed on time, so a retention gap turns into a disclosure allegation
- The five-year Chapter III retention runs alongside the separate eight-year retention for the structured digital database under Reg 3(6), and the two are frequently confused
Recent changes affecting this
Common questions
How long do PIT disclosures have to be kept?
Five years under Reg 6(4). That is not the same as the structured digital database, which Reg 3(6) requires to be kept for eight years and longer while proceedings are on.
Does Reg 6 require any filing?
No. Reg 6 is the general provisions section: the form of a disclosure, the inclusion of immediate relatives, derivatives, and this five-year retention. Every dated PIT disclosure sits in Reg 7.