Notification/Circular No. – Issuer Interface Circular (NSDL) dated December 22, 2025
Applicable Act/Rule – SEBI (Prohibition of Insider Trading) Regulations, 2015
NSDL has released detailed issuer-side operational instructions to implement Trading Window Closure Period for Designated Persons (DPs) and Immediate Relatives, through its Issuer Portal. These guidelines enable automated ISIN-level freeze of securities in DP demat accounts during restricted periods, ensure PAN-based matching across holdings, and also define process for removal, exemption and modification requests with minimum required notice (T-2 basis).
Listed companies must now operationalise trading window closure through NSDL Issuer Portal using defined system workflows. Designated Person lists are auto-populated from SDD; issuers must review, add or delete DPs and Immediate Relatives. The issuer must enter commencement and end dates for each quarter’s closure. NSDL will initiate demat freezes automatically on T-Day. Modifications to end date require two trading days’ advance notice (T-2). Exemptions or removal of specific DPs must also follow T-2. Multiple exemptions are allowed with new auto-enabled fields, but each exemption must maintain minimum T+3 interval.
Also refer to our previous articles – Extension of Automated Trading Window Closure to Immediate Relatives of DPs & Extension of automated implementation of trading window closure to Immediate Relatives of DP
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