Initial disclosure of holdings on appointment
The one-off disclosure of securities held, made by a person on becoming a key managerial person, a director, a promoter or a member of the promoter group.
Initial disclosure on appointment
Counted from appointment as a key managerial person or director, or becoming a promoter or a member of the promoter group
- SEBI
- Insider trading and takeovers
- Form B
- 2026-09-01
Seven days from the appointment. PIT Reg 7(1)(b) requires a person who is appointed as a key managerial person or a director, or who becomes a promoter or a member of the promoter group, to disclose the securities they hold as on the date of appointment to the company within seven days. The old one-time disclosure that used to sit in Reg 7(1)(a) was omitted with effect from 26 April 2021 and no longer exists.
Two common errors attach to this obligation. The first is treating the omitted Reg 7(1)(a) thirty-day disclosure as live; it went on 26 April 2021. The second is expecting an annual disclosure under Chapter III, which has never existed.
Deadlines counted from an event
Within seven days of the appointment or of becoming a promoter, disclose the holding of securities of the company as on the date of appointment or of becoming a promoter. Read with Reg 6(2), the disclosure covers the holdings and trading of immediate relatives as well.
The rule
Within seven days of the appointment or of becoming a promoter, disclose the holding of securities of the company as on the date of appointment or of becoming a promoter. Read with Reg 6(2), the disclosure covers the holdings and trading of immediate relatives as well.
Who must comply
- A person appointed as a key managerial person of a listed company
- A person appointed as a director of a listed company
- A person who becomes a promoter or a member of the promoter group
Statutory basis
Before you file
- Get the date of appointment from the board resolution or the letter of appointment.
- Get a demat statement as on that date.
- Collect the holdings of immediate relatives as on that date.
- Get the current form from Annexure 1 to the Master Circular.
How to file
- Record the securities held as on the date of appointment.
- Record the securities held by each immediate relative on that date.
- Give the completed form to the compliance officer within seven days.
- Do not file this disclosure with the stock exchange. It goes to the company.
If you miss it
SEBI adjudicates a failure under section 15A(b) of the SEBI Act, at ₹1 lakh for each day the failure continues, capped at ₹1 crore, and section 15HB is available at up to ₹1 crore where no specific head fits. There is no exchange fine, because the disclosure goes to the company rather than to an exchange, and no PIT provision sits in the LODR fine table.
- Without the opening holding on record the company cannot check later Reg 7(2) disclosures against a baseline, which weakens its own monitoring
- The disclosure is one of the Chapter III records the company has to preserve for five years under Reg 6(4)
Recent changes affecting this
Common questions
Is there still a one-time initial disclosure under Reg 7(1)(a)?
No. That disclosure, which ran to thirty days, was omitted with effect from 26 April 2021 and the consolidated text now shows the sub-regulation as omitted. The live obligation is the seven-day disclosure on appointment under Reg 7(1)(b).
Is there an annual PIT disclosure of holdings?
No. PIT Chapter III has no annual disclosure at all. The annual items in this area sit in Schedule B: the compliance officer's report to the board, and the designated persons' declaration of immediate relatives and material financial relationships.