Lists of persons with UPSI and Chinese wall controls
The lists of employees and other people with whom unpublished price sensitive information is shared, the confidentiality agreements behind them, and the process for bringing a person inside.
Standing duty, no filing date
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
There is no due date and no provision called an insider list. The obligation sits in three places. PIT Reg 9A(2)(d) requires a listed company to maintain a list of all employees and other persons with whom unpublished price sensitive information is shared, and to have confidentiality agreements or serve notice on them. Clause 2 of Schedule B requires Chinese Wall norms in the code of conduct. Clause 15 requires a documented process for bringing a person inside. All three are standing duties.
The obligation is real but its usual name is not. There is no insider list provision. Reg 9A(2)(d) carries the list and the confidentiality agreements, Schedule B clause 2 the Chinese Wall norms, and clause 15 the process for bringing a person inside.
Deadlines counted from an event
Keep a current list of every employee and other person with whom unpublished price sensitive information is shared, with a confidentiality agreement or notice for each, under Reg 9A(2)(d). Keep Chinese Wall norms in the code of conduct under Schedule B clause 2, and a documented process for bringing a person inside under clause 15. None of the three carries a due date.
The rule
Keep a current list of every employee and other person with whom unpublished price sensitive information is shared, with a confidentiality agreement or notice for each, under Reg 9A(2)(d). Keep Chinese Wall norms in the code of conduct under Schedule B clause 2, and a documented process for bringing a person inside under clause 15. None of the three carries a due date.
Who must comply
- Every listed company that shares unpublished price sensitive information internally or with an adviser
- The chief executive or managing director, whom Reg 9A(1) and 9A(2) make responsible for the internal controls
Statutory basis
Before you file
- Identify the functions that routinely handle unpublished price sensitive information.
- Prepare a confidentiality agreement or a notice format.
- Write the Chinese Wall norms into the code of conduct.
- Write down the process for bringing a person inside.
How to file
- Add each person to the list when unpublished price sensitive information is shared with them.
- Get a signed confidentiality agreement, or serve the notice, for each person on the list.
- Keep the list current as people join and leave the information.
- Follow the documented process each time a person is brought inside.
- Do not file the list with SEBI or an exchange. Produce it on demand.
If you miss it
Section 15A(c) of the SEBI Act covers a failure to maintain records the regulations require, at ₹1 lakh for each day the failure continues, capped at ₹1 crore. Section 15HB is available at up to ₹1 crore for the wider control failure under Reg 9A. There is no exchange fine, because none of these is a filing.
- The list under Reg 9A(2)(d) and the structured digital database under Reg 3(5) are separate records, and holding only one of them leaves the other unmet
- A missing confidentiality agreement weakens the company's position where a recipient of the information trades
Recent changes affecting this
Common questions
Is the insider list the same as the structured digital database?
No. The database under Reg 3(5) records each instance of sharing, with time stamps, an audit trail and PANs, and is kept for eight years. The Reg 9A(2)(d) list is the standing roster of people with whom the information is shared, backed by confidentiality agreements. A company needs both.
Is there a regulation called insider list?
No. That phrase appears in practice, not in the regulations. The duty sits in Reg 9A(2)(d) and in clauses 2 and 15 of Schedule B.