SEBI issued a circular on May 16, 2025, announcing it is giving more time to follow some rules from an earlier circular (dated December 17, 2024). These rules were meant to stop the misuse of regulations and make the use of Offshore Derivative Instruments (ODIs) and separate investment portfolios by foreign investors more transparent.
The earlier circular (Dec 17, 2024) introduced the provisions in paragraphs 2.2 to 2.7 that required additional disclosures from ODI subscribers and FPIs.
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Paragraphs 4 and 5 of the said circular, inter-alia, specifies the following:
“4. The provisions of this circular except Para 2.2 to 2.7 shall come into force with immediate effect. Para 2.2 to 2.7 shall come into effect after 5 months from the date of this Circular…….
5. Depositories are advised to put in place appropriate systems, procedures and mechanisms to ensure compliance with the provisions of this Circular within 5 months from the date of this Circular.”
According to that circular, most provisions were to be implemented immediately. The specific provisions in paragraphs 2.2–2.7 were to be implemented after 5 months (i.e., by May 17, 2025). Depositories were directed to prepare supporting infrastructure within the same timeframe.
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Based on feedback from market participants, SEBI has now extended the deadline for compliance to November 17, 2025 to ensure smooth implementation.
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