Publications
One-time Relaxation for Validity of SEBI Observations
09 Apr 2026
- DMD Advocates
- Blog
Acknowledging representations received from industry bodies regarding the difficulties faced by issuers in the backdrop of ongoing geopolitical tensions in the Middle East and consequent subdued investor participation, Securities and Exchange Board of India (SEBI) has determined that several issuers have been compelled to defer, recalibrate, or withdraw their issuance plans, resulting in potential lapses in observation letter validity and duplication of regulatory processes. At present, issuers are required to open a public issue within 12 (twelve) months or 18 (eighteen) months from the date of SEBI’s observations, pursuant to Regulation 44(1) and 59C of the Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018 (ICDR Regulations), respectively. In light of the aforesaid, SEBI has, vide its circular dated April 7, 2026, extended the validity of all SEBI observation letters expiring between April 1, 2026, and September 30, 2026, until September 30, 2026. This is a one-time relaxation effective from April 7, 2026, and is subject to submission of an undertaking from the Lead Manager to the issue confirming compliance with Schedule XVI of the ICDR Regulations while submitting the updated offer document to the Board.
Credits: Shubhangi Bhatnagar (Principal Associate) and Jasmine Brar (Associate)