Designated persons' annual declaration of relatives and relationships
The declaration each designated person gives the company of immediate relatives, persons with a material financial relationship, and phone numbers used.
Declaration once a year, and on change
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
Once a year, and again whenever the information changes. Clause 14 of Schedule B to the PIT Regulations requires designated persons to give the company the names and PANs of their immediate relatives, of persons with whom they share a material financial relationship, and the phone numbers they use, on an annual basis and as and when the information changes. The declaration is internal, with no exchange filing and no fixed date.
Along with the compliance officer's report under clause 1, this is what the widely listed annual code of conduct confirmation actually is. The code of conduct itself is confirmed to the exchange on adoption or amendment, not annually.
Deadlines counted from an event
Designated persons disclose to the company the names and Permanent Account Numbers of their immediate relatives, of persons with whom they have a material financial relationship, and the phone numbers they use, annually and whenever the information changes. Clause 14 sets an annual frequency and no date. The same clause requires one-time disclosure of educational institutions attended and past employers.
The rule
Designated persons disclose to the company the names and Permanent Account Numbers of their immediate relatives, of persons with whom they have a material financial relationship, and the phone numbers they use, annually and whenever the information changes. Clause 14 sets an annual frequency and no date. The same clause requires one-time disclosure of educational institutions attended and past employers.
Who must comply
- Every designated person identified under the company's code of conduct
- The company, which collects and keeps the declarations
Statutory basis
Before you file
- Confirm the current list of designated persons.
- Prepare the declaration format the code of conduct uses.
- Tell each designated person what the declaration has to cover.
How to file
- Collect the names and PANs of immediate relatives.
- Collect the names and PANs of persons with a material financial relationship.
- Collect the phone numbers the designated person uses.
- Collect the educational institutions and past employers once, on becoming a designated person.
- Repeat the declaration each year.
- Update the declaration whenever any of the information changes.
If you miss it
Section 15HB of the SEBI Act applies at up to ₹1 crore, and the company's code of conduct will carry its own consequence for a designated person who does not declare, with any amount collected going to the SEBI Investor Protection and Education Fund under clause 12 of Schedule B.
- Immediate relative PANs feed the depository freeze during a trading window closure, so a stale declaration leaves relatives untouched by the freeze and exposes them to a breach
- A material financial relationship that goes undeclared removes a person SEBI would treat as connected from the company's own monitoring
Recent changes affecting this
Common questions
What is a material financial relationship for this purpose?
Clause 14 uses the term for a relationship in which one person gives or receives, directly or indirectly, a payment such as a loan or a gift from a designated person during the immediately preceding twelve months, equivalent to at least twenty-five percent of that person's annual income. Payments made in the ordinary course of business are outside it.
Why does the company need phone numbers?
So that the numbers used by designated persons are on record if SEBI examines communications during an insider trading investigation. Clause 14 puts the numbers in the same declaration as relatives and financial relationships.