Compliances have taken a backseat during the ongoing lockdown due to Covid-19 pandemic. Regulatory
authorities have granted several relaxations to assist businesses to cope with the unprecedented lockdown and
economic distress. We discuss herein below a few relaxations granted by the Securities and Exchange Board of
India and the Insurance Regulatory and Development Authority of India to ease the compliance distress of the
companies.

1. Relaxations by Securities and Exchange Board of India (SEBI):

a. Relaxation for Disclosure Filings under the SEBI Takeover Regulations: SEBI has relaxed the timelines for
disclosure filings required to be made under the SEBI (Substantial Acquisition of Shares and Takeovers)
Regulations, 2011 (“Takeover Regulations”) vide circular dated March 27, 2020. In terms of regulations
30(1), 30(2) and 30(4) of the Takeover Regulations, the shareholders of a company are required to compile,
collate and disseminate information of their consolidated shareholding, as on March 31, 2020, to the
company as well as to the stock exchange. In view of the Covid-19 pandemic, the due date for the said
disclosure filings has been extended to June 1, 2020.

b. Extension of Timelines under the Alternative Investment Fund (“AIF”) Regulations: In terms of the circular
issued by SEBI on March 30, 2020, SEBI has extended the due date for regulatory filings for AIFs and
venture capital funds, for the period ending March 31, 2020 and April 30, 2020, by two months over and
above the timelines prescribed under the SEBI (Alternative Investment Fund) Regulations, 2012.

c. Extension of Implementation of the Stewardship Code: SEBI in its circular dated December 24, 2019 had
introduced a Stewardship Code for all mutual funds and all categories of AIFs, in relation to their investment
in liquid entities. The said Stewardship Code was due to come into effect from April 1, 2020. Upon
consideration of the representations received from the Association of Mutual Funds of India and the Indian
Association of Alternative Investment Funds, on account of the Covid-19 pandemic, SEBI vide circular
dated March 30, 2020, extended the timeline for implementation of the Stewardship Code from April 1,
2020 to July 1, 2020.

d. Relaxation under LODR Regulations: SEBI vide circulars dated March 19, 2020, March 23, 2020 and March
26, 2020 has provided relaxation from compliances under certain provisions of the SEBI (Listing Obligations
and Disclosures Requirements) Regulations, 2015 (“LODR Regulations”), as listed below.

Requirement:

• Compliance certificate on share transfer facility [Regulation 7(3)]
• Statement of investor complaints [Regulation 13(3)]
• Meetings of committees [Regulations 19(3A), 20 (3A) and 21 (3A)]
• Secretarial compliance report (Regulation 24A read with circular dated 8 February (2019)
• Corporate governance report [Regulation 27(2)]
• Shareholding pattern (Regulation 31)
• Quarterly/ Annual financial results (Regulation 33)
• Certificate on issuance of share certificates [Regulation 40(9)]
• Exemption for publication of advertisements (Regulation47)
• Holding AGMs of top 100 listed companies [Regulation 44(5)]
• Half-yearly/ annual financial results [Regulations 52(1) and 52(2)]

Relaxation:

• The due date for filing the half-yearly compliance certificate on the share transfer facility has been extended from April 30, 2020, to May 31, 2020.
• The due date for filing the quarterly statement of investor complaints has been extended from April 21, 2020 to
  May 15, 2020.
• An extension of 3 months has been granted for meeting the requirement of holding at least one meeting a year of the nomination and remuneration committee, stakeholders’ relationship committee and risk management committee. This requirement can now be met by June 30, 2020.
• The due date for filing the annual secretarial compliance the report has been extended from May 30, 2020 to June 30,2020.
• The due date for filing the quarterly corporate governance report has been extended from April 15, 2020 to May 15, 2020.
• The due date for filing the quarterly shareholding pattern has been extended from April 21, 2020 to May 15, 2020.
• The due date for filing the quarterly financial results has been extended from May 15, 2020 to June 30, 2020.
  The due date for filing the annual financial results has been extended from May 30, 2020 to June 30, 2020.
• The due date for filing the certificate from a practicing company secretary on timely issuance of share
  certificates has been extended from April 30, 2020, to May 31, 2020.
• The requirement of publishing information such as notice of the board meeting, financial results etc., in the
  newspapers has been exempted for all events scheduled till May 15, 2020.
• The due date for holding the annual general meetings of the top 100 listed companies by market capitalization (determined as of 31 March of each financial year) has been extended from August 31, 2020 to September 30,
  2020.
• The due date for filing the half yearly financial results of companies which have issued listed Non-Convertible
  Debentures/Non-Convertible Redeemable Preference Shares/Commercial Papers, has been extended from
  May 15, 2020 to June 30, 2020.
• The due date for filing the annual financial results of companies which have issued listed NCDs/ NCRPS/
  CPs has been extended from May 30, 2020 to June 30, 2020.

Relaxations by Insurance Regulatory and Development Authority of India (IRDA):
a. Submission of Returns by Insurers – In view of the Covid-19 pandemic, the IRDAI vide circulars dated April
4, 2020 has granted additional time to all insurers for submission of regulatory returns to be submitted as
at March 31, 2020. Fifteen days additional time has been granted for submission of monthly returns and
30 days additional timeline has been granted for submission of quarterly, half-yearly and yearly returns and
cyber security audit. The timeline for submission of monthly and quarterly returns for the month of March
2020 by insurers and insurance intermediaries under the relevant regulations has been extended by a
period of 15 days.
b. Submission of Returns by Insurance Intermediaries: For the regulatory returns which are required to be
filed by insurance intermediaries, IRDAI vide circular dated April 9, 2020 has allowed 30 days additional
time for submission of half-yearly and yearly returns and cyber security audit.
c. Submission of Final Re-insurance Programme – In compliance with the regulations, insurers are required
to file their respective board approved final re-insurance programme for the financial year 2020-21 by April
30, 2020 along with a synopsis of catastrophe modelling report. The timeline for submission of the board
approval re-insurance programme has been extended till May 31, 2020, vide IRDIA circular of March 28,
2020.
d. Relaxations for Policy Holders – IRDAI vide notification dated April 1, 2020 has directed the health insurers
to permit the policy holders, whose policies are due to be renewed between March 25, 2020 to April 14,
2020, to pay the premium for renewal of their respective policy on or before April 21, 2020 and the health
insurers have been directed to ensure continuity of health insurance cover from the date on which the policy
falls due for renewal. Similarly, even if the motor vehicle third party insurance is due to be renewed during the period from March 25, 2020 to April 14, 2020, the insurers have been directed to allow the policy holders to pay the premium on or before April 21, 2020 and ensure continuity of the statutory motor vehicle third party insurance cover
from the date on which the policy falls due for renewal.

For more Covid 19 related legal updates, please refer to https://lexcounsel.in/newletters/newsletters-2020/ and for
Covid 19 related articles, please refer to https://lexcounsel.in/articles-2020/