Prior intimation of an exempt acquisition
The advance notice an acquirer gives the exchanges before an acquisition it treats as exempt from the open offer requirement.
Prior intimation to the exchanges
Counted from the proposed acquisition, counted backwards from it
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
At least four working days before the proposed acquisition. SAST Reg 10(5) requires an acquirer relying on an exemption to give the stock exchanges where the target's shares are listed a disclosure in the prescribed form at least four working days before the acquisition. This is a separate filing from the Reg 10(6) report that follows the acquisition, and the two are often collapsed into one.
Deadlines counted from an event
At least four working days before the proposed acquisition, disclose it in the prescribed form to every stock exchange where the target's shares are listed. Reg 10(5) counts the four working days backwards from the acquisition, so the filing comes first and the acquisition follows.
The rule
At least four working days before the proposed acquisition, disclose it in the prescribed form to every stock exchange where the target's shares are listed. Reg 10(5) counts the four working days backwards from the acquisition, so the filing comes first and the acquisition follows.
Who must comply
- An acquirer relying on an exemption under Reg 10 for a proposed acquisition
Statutory basis
Before you file
- Identify the sub-regulation of Reg 10 the exemption rests on.
- Confirm the proposed date of the acquisition.
- Get the prescribed form from the SAST master circular.
- Check whether the exemption also needs a Reg 10(7) report to SEBI with a fee.
How to file
- Count four working days back from the proposed acquisition date.
- File the prescribed form with every stock exchange where the target's shares are listed on or before that date.
- Complete the acquisition on or after the proposed date.
- File the Reg 10(6) report after the acquisition, which is a separate filing.
If you miss it
Section 15A(b) of the SEBI Act applies at ₹1 lakh for each day the failure continues, capped at ₹1 crore, and section 15HB at up to ₹1 crore. The larger risk is to the exemption itself: an acquisition made without the prior intimation the exemption is conditioned on can be treated as one that needed an open offer, which brings section 15H into play at ₹25 crore or three times the profit made.
- Reg 10 exemptions are conditional, so a missed procedural filing can turn an exempt acquisition into an open offer default
- The Reg 10(6) post-acquisition report is still due even where the prior intimation was filed
Common questions
Is Reg 10 exemption reporting one filing or two?
At least two. Reg 10(5) is a prior intimation to the exchanges at least four working days ahead, and Reg 10(6) is a report to the exchanges within four working days after the acquisition. Specified exemptions add a third, the Reg 10(7) report to SEBI with a fee.