Operating Guidelines for Lock-in / Non-transferability of Pre-IPO Securities

Notification / Circular No.: NSDL/CIR/II/19/2026 dated April 07, 2026

Applicable Act / Rule: Securities and Exchange Board of India (Issue of Capital and Disclosure Requirements) Regulations, 2018

Issuers and Registrar & Transfer (R&T) Agents are subject to lock-in requirements for specified securities issued prior to initial public offering under SEBI ICDR Regulations. The Gazette Notification dated March 16, 2026 amended the framework to address cases where lock-in cannot be created in the usual manner. This circular operationalises the amended requirement through depository-level mechanisms.

SEBI has provided under Regulation 17(2)(1) that:

“where lock-in of the specified securities cannot be created, the depositories shall, upon receipt of instructions from the issuer, record such securities as ‘non-transferable’ for the duration of the applicable lock-in period.”

Accordingly, NSDL has introduced system enhancements enabling Issuers and R&T Agents to:

  • Incorporate lock-in for securities issued prior to IPO even if such securities are in pledge or freeze status
  • Record such securities as “non-transferable” upon issuer instructions
  • Freeze such securities for the entire lock-in period

This facility is in addition to the existing corporate action mechanism available for lock-in of securities in the NSDL depository system.

Detailed operating guidelines are provided in Annexure-B of the circular.

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