Identifying unpublished price sensitive information
The sixteen categories of information that count as unpublished price sensitive information, and which therefore drive database entries, trading window closure and pre-clearance.
Standing duty, no filing date
- SEBI
- Insider trading and takeovers
- Not specified
- 2026-09-01
There is no date to meet here. PIT Reg 2(1)(n) defines unpublished price sensitive information, and the definition applies from the moment the information exists. What changed is its size: the SEBI (PIT) (Amendment) Regulations, 2025 took effect on 10 June 2025 and grew the list from five illustrative items to sixteen. Explanation 2 reads the materiality guidelines in LODR Schedule III Part A into that list, so an event that is material for Reg 30 is the starting point for deciding whether information is price sensitive.
The SEBI (PIT) (Amendment) Regulations, 2025 were notified on 11 March 2025, published on sebi.gov.in on 12 March 2025, and took effect on 10 June 2025. Guidance written before that date describes a five-item definition and is now short by eleven categories.
Deadlines counted from an event
Information relating to a company or its securities that is not generally available and that, once available, is likely to materially affect the price. Reg 2(1)(n) lists sixteen categories from 10 June 2025, against five before that date. Explanation 1 covers the sub-clauses; Explanation 2 applies the LODR Schedule III Part A materiality guidelines to identify the events. The classification is made when the information arises, not on a periodic review.
The rule
Information relating to a company or its securities that is not generally available and that, once available, is likely to materially affect the price. Reg 2(1)(n) lists sixteen categories from 10 June 2025, against five before that date. Explanation 1 covers the sub-clauses; Explanation 2 applies the LODR Schedule III Part A materiality guidelines to identify the events. The classification is made when the information arises, not on a periodic review.
Who must comply
- Every listed company, which has to identify price sensitive information before it can log an SDD entry or close a trading window
- Every insider, designated person and connected person, whose trading and communication restrictions turn on this definition
- Intermediaries and fiduciaries who receive such information from a listed company
Statutory basis
Before you file
- Read the sixteen sub-clauses of Reg 2(1)(n).
- Read the LODR Schedule III Part A materiality guidelines that Explanation 2 applies.
- Identify who inside the company first learns of each category of event.
How to file
- Test the information against the sixteen sub-clauses of Reg 2(1)(n).
- Apply the LODR Schedule III Part A materiality guidelines where the sub-clause names an event.
- Record the sharer and the recipient in the structured digital database.
- Close the trading window where the information emanates from within the company.
- Do not close the trading window where the information does not emanate from within the company.
- Do not file this classification with SEBI or an exchange. It is an internal judgement that the records have to support.
If you miss it
Misclassification is not itself penalised. What follows from it is. Trading while in possession of unpublished price sensitive information attracts section 15G of the SEBI Act, at ₹25 crore or three times the profit made, whichever is higher. Communicating it outside the ordinary course of business sits under the same section. Where the failure is a record or process gap rather than a trade, the head is section 15HB, up to ₹1 crore.
- An event treated as not price sensitive is an event with no database entry and no window closure, so one wrong classification produces several breaches at once
- The sixteen-item list overlaps LODR Regulation 30, so the same event usually carries a disclosure deadline to the exchanges as well
Recent changes affecting this
Master Circular on Surveillance of Securities Market
Relaxation from SEBI Master Circular for Minimum Public Shareholding Non-Compliance
Master Circular for compliance with the provisions of the Securities and Exchange Board of India (Listing Obligations and Disclosure Requirements) Regulations, 2015 by listed entities
Master Circular for listing obligations and disclosure requirements for Non-convertible Securities, Securitized Debt Instruments and/ or Commercial Paper
Common questions
How many categories of UPSI are there now?
Sixteen, from 10 June 2025. Before that the definition carried five illustrative items, which is the figure most published guidance still uses.
What did the 2025 amendment add?
Award or termination of orders and contracts outside the normal course went into sub-clause (iv), and sub-clause (v) now carves out superannuation and end of term while adding the resignation of a statutory or secretarial auditor. The new sub-clauses (vi) to (xvi) cover rating changes other than ESG ratings, proposed fund raising, agreements that affect management or control, fraud or default or arrest, a resolution plan or one-time settlement, winding-up or admission to insolvency resolution, the start of a forensic audit and its final report, regulatory or judicial action, litigation outcomes, guarantees and indemnities outside the normal course, and the grant, withdrawal or suspension of a key licence.
Does an event have to be material to be price sensitive?
Explanation 2 sends you to the LODR Schedule III Part A materiality guidelines to identify the events in the list, so the two tests are deliberately linked. The Reg 2(1)(n) test is still its own: the information must be not generally available and likely to materially affect the price.