The executive brief
The decision in front of the business.
01SEBI’s 13 October paper concerns the monitoring and disclosure of issue-proceeds utilisation under the ICDR and LODR frameworks.
02The consultation includes working-group recommendations and SEBI’s additional proposals concerning direct reporting by monitoring agencies, issuer non-cooperation and continuity when an agency engagement changes.
03Comments are invited by 3 November 2026 without a stated clock time. Final obligations, commencement and transition must follow the eventual operative instruments, not the consultation alone.
- First published
- Underlying event
- Source checked
Industry, model and participation details
Financial Services, Capital Markets & InsuranceGovernance & AdminInfrastructure & Urban DevelopmentDevelopment context
The facts that shape the opportunity.
Consultation scope and principal themes
The paper addresses Chapter I of the working-group review: monitoring and utilisation disclosure. Its summary includes direct agency reporting to exchanges, a statement where issuer cooperation is lacking, continuity during agency transition and closer alignment of ICDR and LODR reporting provisions. The broader report’s other chapters are not the subject of this consultation.
Securities and Exchange Board of India ↗Proposed framework, not current amendment
The paper discusses changes around Regulation 32 and a proposed separate Regulation 32A, together with reporting formats and transition. It invites reasoned public comments by 3 November 2026. These proposals do not become binding merely through publication of the consultation.
Securities and Exchange Board of India ↗TLGS assessment
Commercial and operating implications.
Make the evidence trail usable by the monitoring function
An issuer’s readiness assessment should connect the approved objects of the issue, banking and accounting records, expenditure evidence, internal authorisation and disclosure review. The objective is a consistent explanation of how proceeds are used. Avoid assuming that a proposal changes existing reporting thresholds or exemptions until the final instrument is examined.
Agency transition should not create a reporting gap
Review the contract and internal ownership of records so that a change in monitoring arrangements does not leave unanswered responsibility for a reporting period. Document handover, access and escalation. The consultation makes this a relevant policy-response question; the issuer’s applicable present obligations and the agreed contract remain the immediate operating framework.
Separate the proposal’s layers before responding
A consultation containing working-group recommendations and additional regulator proposals should not be compressed into one unqualified statement of new law. Identify which provision is under discussion, its proposed application, transition and operational impact. A useful submission can explain where clearer allocation of issuer, agency and exchange responsibilities would improve compliance without weakening accountability.
From insight to action
Priorities for leadership.
Issuer finance and compliance teams
Map issue objects, use-of-funds evidence and responsibility for disclosure preparation.
Audit committees and monitoring agencies
Review cooperation, escalation and continuity of reporting arrangements.
Policy and legal teams
Submit provision-specific comments by 3 November and track the final instruments.
Project and policy milestones
What changes the next decision.
The 3 November comment date, subsequent SEBI decisions, notified amendments and stated commencement or transition provisions.
Reference documents
Sources and further reading.
- Official consultation PDFIssue proceeds: monitoring and utilisation-disclosure consultation ↗Securities and Exchange Board of India · 13 October 2026
10-page consultation on Chapter I of the working-group review, including SEBI’s additional proposals. Public comments by 3 November 2026, without a stated clock time; proposed requirements are not in force merely because consulted upon.