Compliance Requirements under the Regulations

1. General Provisions for Insider Trading (Regulation 6)

All public disclosures under this Chapter shall be made in the prescribed form. Disclosures shall include trades executed by the person concerned, their immediate relatives, and any other person for whom such person takes trading decisions. The focus of disclosure is on the person taking trading decisions, particularly where such person is in possession of unpublished price sensitive information. Disclosures shall also cover trading in derivatives of securities, and the traded value of such derivatives shall be considered, where such trading is permitted under applicable law.
All disclosures made under this Chapter shall be preserved by the company for a minimum period of five years in the specified form.

2. Initial Disclosures and Continual Disclosures (Regulation 7)

Regulation 7(1) and 7(2) of under SEBI (Prohibition of Insider Trading) Regulations, 2015 talks about disclosures by certain persons which can be initial and continual. The provisions with respect to the same are detailed herein below:

         A. Initial Disclosures under Regulation 7(1):

Every person on appointment as key managerial personnel or a director of the company or upon becoming a promoter or member of the promoter group] shall disclose his holding of securities of the company as on the date of appointment or becoming a promoter, to the company within seven days of such appointment or becoming a promoter.

B. Continual Disclosures under Regulation 7(2):

1. 1. Every promoter  member of the promoter group] [designated person] and director of every company shall disclose to the company the number of such securities acquired or disposed of within two trading days of such transaction if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of ten lakh rupees or such other value as may be specified.
   2. Every company shall notify the particulars of such trading to the stock exchange on which the securities are listed within two trading days of receipt of the disclosure or from becoming aware of such information.
   3. The above disclosures shall be made in such form and such manner as may be specified by the Board from time to time.

C. Disclosures by other connected persons under Regulation 7(3):

Any company whose securities are listed on a stock exchange may, at its discretion require any other connected person or class of connected persons to make disclosures of holdings and trading in securities of the company in such form and at such frequency may be determined by the company in order to monitor compliance with these regulations.

Penalty & Punishment

Reg 10 provides that any contravention under the PIT Regulations shall be dealt by SEBI as per SEBI Act, 1992.

Sec 15A of SEBI Act:

If any person, who is required under this Act or any rules or regulations made thereunder,—

(a)  to furnish any document, return or report to the Board, fails to furnish the same [or who furnishes or files false, incorrect or incomplete information, return, report, books or other documents], he shall be liable to [a penalty [which shall not be less than one lakh rupees but  which  may  extend  to  one  lakh  rupees  for  each  day  during  which  such failure continues subject to a maximum of one crore rupees 

(b)  to file any return or furnish any information, books or other documents within the time specified therefor in the regulations, fails to file return or furnish the same within the time specified  therefor  in  the  regulations [or  who  furnishes  or  files  false,  incorrect  or incomplete information, return, report, books or other documents, he shall be liable to penalty which shall not be less than one lakh rupees but which may extend to one lakh rupees for each day during which such failure continues subject to a maximum of one crore rupees.