New SEBI Informal Guidelines

SEBI has introduced new Informal Guidance Scheme, 2025 (“New Scheme”), replacing the two-decade-old framework first issued in 2003 (“Old Scheme”). Effective December 1, 2025, the New Scheme modernises the informal guidance process to reflect the significant evolution of India’s securities market, expanding eligibility to include contemporary stakeholders such as managers of pooled investment vehicles and market infrastructure institutions (“MIIs”).

In addition to widening the pool of eligible applicants, the New Scheme brings several key changes, including:

  1. Inclusion of MIIs as applicants;
  2. Mandatory electronic filing through a designated nodal cell;
  3. Introduction of a standardised application format (Schedule I);
  4. Application and processing fees (with deductions for rejected/withdrawn applications);
  5. Stricter timelines for applicant to provide responses; and
  6. Strengthened confidentiality safeguards through permitted redactions.

Overall, the New Scheme marks a significant shift toward a more structured and contemporary regulatory framework. By digitising processes, expanding access to entities such as MIIs and AIF managers, and enforcing clearer timelines, SEBI has streamlined the interpretive mechanism to reduce ambiguity and administrative delays.