Quick summary
This consultation paper from SEBI proposes simplifying documentation for transmitting securities and revising threshold limits for simplified documentation. It aims to ease claims for survivors, standardize procedures, and remove mandatory probate in certain jurisdictions. Public comments are invited by April 02, 2026.
Who is affected
The proposed framework shall apply to:
- Listed companies
- Registrars to an Issue and Share Transfer Agents (RTAs)
- Depositories
- Depository Participants (DPs)
- Asset Management Companies (AMCs)
- Claimants/investors seeking transmission of securities
What changes
- Objective: Simplify documentation requirements for transmission of securities and revise limits for simplified documentation.
- Probate Requirement: Mandatory probate requirement was abolished w.e.f. December 20, 2025, for Hindus, Buddhists, Sikhs, Jains, and Parsis in Mumbai, Chennai, and Kolkata, making probate optional.
- Revised Monetary Threshold Limits:
- Securities in physical mode / MF units (per listed entity/AMC):
- Existing simplified documentation limit: ₹5 lakhs
- Proposed simplified documentation limit: ₹10 lakhs
- Proposed straight-through processing limit (new category): ₹10 thousand
- Securities in dematerialised mode (per beneficial owner):
- Existing simplified documentation limit: ₹15 lakhs
- Proposed simplified documentation limit: ₹30 lakhs
- Proposed straight-through processing limit (new category): ₹30 thousand
- Listed entities may, at their discretion, enhance the value of securities from the threshold limit of rupees ten lakhs for physical mode securities.
- Standardised Documentation Requirements:
- Where nomination has been made: Transmission request form by nominee, latest client master list (CML) of demat account (not older than two months, attested by DP), verifiable death certificate, and officially valid ID proof of the nominee.
- Where there is no nomination / no will:
- Straight Through Processing (low value cases): Duly signed transmission request form, latest CML (not older than two months, attested by DP), verifiable death certificate, officially valid ID proof of claimant, and an undertaking on plain paper (as per specified format).
- Simplified cases (other than Straight Through Processing): Duly signed transmission request form, latest CML (not older than two months, attested by DP), verifiable death certificate, officially valid ID proof of claimant, notarized indemnity bond, and NOC from all legal heir(s) or copy of family settlement deed (attested by notary public or gazetted officer).
- Cases above threshold: Duly signed transmission request form, latest CML (not older than two months, attested by DP), verifiable death certificate, officially valid ID proof of the claimant, a notarized affidavit from all legal heir(s) on non-judicial stamp paper, and Copy of Succession certificate or Letter of Administration or Court Decree OR Copy of Will along with notarized indemnity bond OR Legal Heirship Certificate or its equivalent along with notarized indemnity bond and NOC from all non-claimants.
- Standardisation of Procedure for Submission of Claims:
- Entities shall use standardised SEBI forms (physical and on websites).
- Acknowledgement of claim receipt and immediate notification of pending/missing/incomplete documents.
- Confirmation upon receipt of all required documents.
- Online facility for claims may be offered, with online tracking. Original documents may require in-person presentation.
- Deviations from procedure must be communicated in writing with reasons.
- Additional Modes for Proof of Death Outside India:
- Proposed to add certification by authorised officials of overseas branches of Scheduled Commercial Banks registered in India, and certification by authorised officials of any foreign bank.
- Time Limit for Settlement of Claims:
- Entities shall process transmission cases within 21 calendar days (or as specified by the Board) from the date of receipt of all required documents.
- Reasons for delay/rejection must be communicated in writing.
- LODR Regulations Amendment: Proposed to delete Para C of Schedule VII of LODR regulations and issue provisions through a circular, with suitable amendments to regulation 40(7) and 61(4) of LODR Regulations and Para 21 of the Master Circular.
Action items
- Public comments/views/suggestions are invited on the proposals (paragraphs A to F).
- Comments/suggestions along with rationale should be submitted through the specified link or email.
Key dates-deadlines
- March 12, 2026: Consultation Paper Issued.
- April 02, 2026: Deadline for submitting public comments.
- December 20, 2025: Mandatory probate requirement abolished (effective date).
- Within 21 calendar days: Time limit for entities to process transmission claims from the date of receipt of all required documents.
Source reference
Consultation Paper, March 12, 2026