Structured Digital Database
A running internal record of who received unpublished price sensitive information, kept with time stamps and an audit trail, and preserved for eight years.
Standing duty, no filing date
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
The Structured Digital Database has no due date. PIT Reg 3(5) makes it a standing duty: the board of directors or the head of the organisation maintains it at all times, with the names and PANs of everyone who shared or received unpublished price sensitive information. Reg 3(6) requires the database to be preserved for eight years, and longer while an investigation is on. From 10 June 2025, information that does not come from inside the organisation may be entered up to two calendar days from receipt.
The database itself has not changed since the 2020 amendment, but two things around it did. The SEBI (PIT) (Amendment) Regulations, 2025 took effect on 10 June 2025 and added the two-calendar-day entry window for information that does not emanate from within the organisation. The same amendment expanded the definition of unpublished price sensitive information in Reg 2(1)(n) from five categories to sixteen, which widens what has to be logged.
Deadlines counted from an event
Maintain the structured digital database at all times. PIT Reg 3(5) sets no periodic due date. Entries are made as unpublished price sensitive information is shared or received, with time stamps and an audit trail that cannot be tampered with. For information that does not emanate from within the organisation, a proviso effective 10 June 2025 allows entry up to two calendar days from receipt. Reg 3(6) requires preservation for eight years after the relevant transactions, and longer if proceedings are on.
The rule
Maintain the structured digital database at all times. PIT Reg 3(5) sets no periodic due date. Entries are made as unpublished price sensitive information is shared or received, with time stamps and an audit trail that cannot be tampered with. For information that does not emanate from within the organisation, a proviso effective 10 June 2025 allows entry up to two calendar days from receipt. Reg 3(6) requires preservation for eight years after the relevant transactions, and longer if proceedings are on.
Who must comply
- Every listed company, through its board of directors or head of the organisation
- Any intermediary or fiduciary that handles unpublished price sensitive information of a listed company
Statutory basis
- PIT Reg 3(5), structured digital database, and Reg 3(6), eight-year preservation
- PIT Regulations, 2015, consolidated text as amended to 12 March 2025 (PDF)
- PIT Reg 2(1)(n), definition of unpublished price sensitive information, sub-clauses (i) to (xvi)
- Master Circular on Surveillance of Securities Market
Before you file
- Get board approval for the person or function that maintains the database.
- Collect the name and PAN of each person who shares unpublished price sensitive information.
- Collect the name and PAN of each person who receives that information.
- Confirm that the software keeps time stamps and an audit trail.
- Confirm that the software does not permit an entry to be changed or deleted after it is made.
- Confirm that the database is not kept outsourced.
How to file
- Identify the information as unpublished price sensitive information under Reg 2(1)(n).
- Enter the sharer, the recipient and the nature of the information in the database.
- Enter the record on the same day for information that comes from inside the organisation.
- Enter the record within two calendar days of receipt for information that comes from outside the organisation.
- Keep the database entries for eight years after the relevant transactions.
- Keep the entries longer if an investigation has started.
- Do not file the database with SEBI or an exchange. Produce it on demand.
If you miss it
There is no per-day exchange fine for this one, because the database is not a filing and Reg 3(5) is not on the exchange fine list. SEBI adjudicates it itself. The PIT Regulations set no penalty of their own, so the head is section 15HB of the SEBI Act, which allows a penalty of up to ₹1 crore for a contravention with no separate penalty prescribed. Where SEBI has to ask for the database and it does not hold what Reg 3(5) requires, section 15A of the SEBI Act is also available at ₹1 lakh for each day of the failure, capped at ₹1 crore. Amounts in practice are well into lakhs: a managing director of a listed company settled a Reg 3(5) proceeding at ₹23.43 lakh in March 2026, and a merchant banker settled one at ₹58.50 lakh in May 2026.
- The proceeding runs against the board of directors or the head of the organisation, not the company alone, because Reg 3(5) puts the duty on them
- SEBI can close a lesser lapse with an administrative warning letter instead, which the entity then has to disclose to the exchanges as a material event
- A gap in the database undercuts the entity's own defence in an insider trading investigation, where the database is the primary record of who held the information and when
Common questions
When is the Structured Digital Database due?
It is never due, because it is not a filing. Reg 3(5) requires it to exist and to be current, so the test is whether it is complete and tamper-proof on the day someone asks for it.
Is there any deadline attached to it at all?
Two. Entries for information that does not come from inside the organisation may be made up to two calendar days from receipt, under a proviso effective 10 June 2025. And the database has to survive eight years under Reg 3(6), longer if proceedings are on.
What has to go in it?
The names and PANs, or other identifiers where a PAN does not exist, of everyone who shared unpublished price sensitive information and everyone who received it. The 2025 amendment widened Reg 2(1)(n) from five categories to sixteen, so the range of information that has to be logged grew with it.
Can the database be outsourced?
No. Reg 3(5) requires the board of directors or the head of the organisation to maintain it internally, with time stamps and a non-tamperable audit trail.