Trading window freeze details to the depository
The company-side step behind the depository freeze: giving the designated depository the PANs of designated persons and their immediate relatives, and the window start and end dates for each results cycle.
Standing duty, no filing date
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
There is no single statutory date for this one. Paragraph 5.2 of the Master Circular on Surveillance of Securities Market makes it a per-cycle duty: before each trading window closure the company confirms the PANs of its designated persons and their immediate relatives with the designated depository, and gives the depository the window start and end dates so the holdings can be frozen at ISIN level. The framework was extended to immediate relatives in April 2025.
The framework used to reach designated persons only. Circular SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55 dated 21 April 2025 extended it to their immediate relatives, so the PAN set a company has to keep current is materially larger than it was.
Deadlines counted from an event
Keep the designated person and immediate relative details filed with the designated depository current, and give the depository the trading window start and end dates for each results cycle in time for the freeze to take effect. Paragraph 5.2 and Annexure 4 of the Master Circular on Surveillance of Securities Market set the process and the formats. The circular fixes the process, not a number of days from a period end.
The rule
Keep the designated person and immediate relative details filed with the designated depository current, and give the depository the trading window start and end dates for each results cycle in time for the freeze to take effect. Paragraph 5.2 and Annexure 4 of the Master Circular on Surveillance of Securities Market set the process and the formats. The circular fixes the process, not a number of days from a period end.
Who must comply
- Every listed company whose trading window closes for the declaration of financial results
- Designated persons and their immediate relatives, whose PANs the company has to supply
Statutory basis
Before you file
- Identify the designated persons for the current cycle.
- Collect the PAN of each designated person.
- Collect the PAN of each immediate relative of a designated person.
- Get the board meeting date for the results declaration.
- Get access to the designated depository's submission facility.
How to file
- Confirm the designated person and immediate relative details with the designated depository.
- Submit the trading window start date and end date in the prescribed format.
- Check that the depository applied the freeze at ISIN level.
- Tell the depository the actual reopening date after the results are declared.
- Correct any PAN the depository reports as invalid.
If you miss it
The circular carries no fee of its own. A company that does not supply the details leaves the freeze unenforced, and SEBI adjudicates that under section 15HB of the SEBI Act, which allows a penalty of up to ₹1 crore where no separate penalty is prescribed. Where SEBI or the depository has called for the details and the company has not supplied them, section 15A is also available at ₹1 lakh for each day of the failure, capped at ₹1 crore.
- Without the freeze the trading window closure depends entirely on designated persons policing themselves, and a resulting trade becomes a code of conduct breach the company then has to report to the exchange
- Wrong or stale PAN data can freeze the holdings of someone who is no longer a designated person, which the company has to unwind with the depository
Recent changes affecting this
Common questions
Is there a deadline for giving the depository the freeze details?
Not one this record can state. The Master Circular sets the process and the formats and expects the details to be with the designated depository before the freeze takes effect, which in practice means a few days ahead of the closure. We have not sourced a specific number of days, so none is shown.
Does this cover immediate relatives?
Yes, since April 2025. Circular SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55 dated 21 April 2025 extended the PAN-ISIN freeze to immediate relatives of designated persons, and it is now consolidated into the Master Circular on Surveillance of Securities Market.