Summary of Changes to SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015-Implications of Changes.
Vide Circular dated May 10, 2018, SEBI have notified changes to the above Regulations, in partial acceptance of the some of the recommendations made by the Uday Kotak Committee on Corporate Governance in its Report which was submitted to SEBI on October,5, 2017. The Report was subsequently placed in the public domain and responses from stakeholders were elicited till November, 4, 2017.
A summary of the changes accepted by SEBI and their implications is given in this exposition. It is pertinent to note that to facilitate transition to the revised regime the provisions have been made prospective with most of the changes kicking in from April,1, 2019.Some of the changes have applicability from October,1, 2018.The changes have a wide ramification and will certainly have the effect of raising the bar on disclosure requirements by some notches and also usher in, hopefully , a superior quality of corporate governance ,considering the stringent regime of disclosure in anvil. For facility of appreciation of the nuances of the changes proposed, this exposition is split into two parts, one which gives the reader an overview of the non-mandatory proposals and the other which deals incisively with the mandatory requirements and their implications.
Non-Mandatory Proposals:
The following changes may be considered by a listed company voluntarily:
Disclosures in the Annual Report on Board Evaluation
The following disclosures may be considered in the Annual Report:
Observations on Board Evaluation carried out for
the year
Previous year's observations and actions taken thereon.
Proposed actions based on current year's observations
Group Governance Unit
Where the listed company has a number of unlisted subsidiaries, the Company may monitor the governance of the subsidiaries, either through a dedicated group governance unit or a governance committee consisting of Board Members.
The Company may also establish a strong and effective group governance policy. The decision to set up a group committee/unit or having a group policy shall rest with the Board of the Company.
Medium Term and Long Term Strategy
The following disclosures may be made in the Board's Report with regard to the Company's Medium Term and Long Term Strategy:
As part of the Section on Management Discussion and Analysis, the disclosure on Medium Term and Long Term Strategy within the limits set by the firm's competitive position based on a time frame to be decided by the Board.
Articulation of Long Term metrics specific to the Company's Long Term Strategy to facilitate appropriate measurement of progress.
The above changes can be embraced voluntarily by a company from April,1, 2019.
Mandatory Changes as notified:
Save as otherwise specifically stated in the regulations, the changes notified shall come into force from April 01, 2019
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Amendments and Implications |
Time lines |
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Regulation 2(1)(zb) - Definition of Related Party The definition is being extended to include any person or entity belonging to the promoter or promoter group and who holds 20 % or more in the share capital. Implication-As the definition is being widened in amplitude, it will be necessary for Companies to re-map the list of related parties to cover the above genre of persons. |
W.e.f. 01.04.2019 |
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Regulation 16 (1)(b)(ii) and (viii) - Definition of Independent Director Existing definition is being tightened to clarify that any person who is a member of the promoter group of the company shall also not be considered as an Independent Director. This change is in sync with Section 149 of the Companies Act, 2013 (hereinafter “the Act'). Further, any person who is an Independent Director , shall not be a non-independent director of another company on the Board of which a non-independent director of the company is an independent director. Implications: Fresh declarations have to be obtained by Companies from their Independent Directors as of 30.09.2018 incorporating the above requirements.. |
W.e.f. 01.10.2018 |
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Regulation 16 (1)(c): Definition of material subsidiary made more stringent At present a subsidiary of the listed company is to be considered as a “material subsidiary', where the subsidiary's income or net worth exceeds 20% of the consolidated income or net worth of the listed company in the preceding financial year. The above threshold is being reduced to 10%. It is pertinent to note that consequent upon the above . many more unlisted subsidiaries shall come within the ambit of a “material subsidiary' due to the reduced threshold as above. It is also important to note that the threshold for determining materiality of a subsidiary has been retained at the existing threshold of 20% for the purposes of Regulation 24(1) which interalia, prescribes that an Independent director of the Holding company shall sit on the Board of the Material subsidiary . |
W.e.f. 01.04.2019 |
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Regulation 16 (1)(d): Definition of Senior Management The existing definition of the term “Senior Management' is not specific, in that it is inclusive and covers all members of the Management standing in a hierarchy which is one level below the Executive Directors including all Functional Heads. This definition allows for application of discretion on the part of companies in determining persons who shall form part of “Senior Management'. The definition is being made more specific and shall include the persons occupying positions one level below:
Implications: Arising out of the above , it will be necessary for Companies to re-identify persons who shall be part of Senior Management as per the above. |
W.e.f. 01.04.2019 |
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Regulation 17 - Changes relating to Board of Directors Reg. 17(a) - Woman Director - At present the woman director on the Board need not be an Independent Director. It is proposed that the top 500 listed companies (based on Market cap of the previous FY) shall have at least one Independent Woman Director. The top 1000 listed companies shall have at least one Independent Woman Director. Implications: SEBI has observed that to satisfy the norm for appointing a Woman Director, many reputed companies have resorted to the practice of appointing the spouses of the promoters as directors. To discourage such an approach ,SEBI has ruled that the woman director shall have to necessarily be an Independent director. The transition contemplated shall happen in a phased manner depending on the market capitalization of Companies. Insertion of New Regulation 17(1)(c) - Minimum no. of directors Top 1000 listed companies shall have at least a minimum of 6 directors. Top 2000 listed companies shall have at least a minimum of 6 directors. Implications: Many of the listed company Boards are compact and have a strength which is below the above threshold. Companies will now have to fall in line with the above norm. The Board has to have a reasonable size to ensure that there is a free exchanges of views amongst the directors so that different perspectives are available to facilitate objective decision making by the Board. Insertion of New Regulation 17(1A)-Appointment of non-executive director including Independent Director whose age exceeds 75 years Where it is proposed to either appoint or to continue with the appointment of a non-executive director who is 75 years in age, such appointment shall be by a special resolution of the members and there shall be an explanatory statement in the Notice in justification of such appointment. Implications: Listed Companies normally take recourse to the appointment of retired bureaucrats, Senior Counsels as Independent Directors to lend stature to their Boards. The age bar as contemplated will yield to a more vibrant Board. Insertion of New Regulation 17(1B)- Delinking the position of Chairman and Managing Director The top 500 companies shall ensure that the Chairman of the Board shall be :
The above provision shall not apply to a company which does not have any identifiable promoters as per the shareholding pattern filed with the exchange. Implications: There exist several reputed listed companies who have an executive chairman holding the reins and who doubles up in the capacity of Managing director as well. The above proposal will put an end to this practice Insertion of New Regulation 17(2A)- Quorum for Board Meetings Quorum shall be one third of total strength of the Board or three directors, whichever is higher and shall include at least one independent director. For top 1000 companies(w.e.f.1.4.2019) For top 2000 companies(W.e.f.1.4.2020) Attendance through Video conferencing shall be considered for the purpose of determining quorum. Implications: The above change is primarily intended to align the Listing Regulations with the provisions of the Act. Insertion of New Regulation 17(6)(ca)- Approval of shareholders by special resolution for payment of remuneration to a single non-executive director (w.e.f.1.4.2019) Where the annual remuneration payable to a single non-executive director exceeds 50% of the total annual remuneration payable to all non-executive directors, approval of shareholders by special resolution shall be obtained each year for such payment. Implications: The above proposal will ensure that the disparity in the payments made to non-executive Directors in particular by way of commission based on Net profits is narrowed down and ensure that companies justify such disparity, if any, by seeking consent of the Members. Insertion of New Regulation 17(6)(e)- Compensation to Executive Directors Where the remuneration payable to Executive Directors who are either promoters or members of the promoter group exceeds 5 crores or 2.5% of the net profits of the Company, whichever is higher, or where the company has more than one such director, if the remuneration exceeds 5% of the net profits, such payment will require approval of the shareholders by special resolution. The special resolution shall be valid till the expiry of the term of the director. Implications: The above proposal is salutary in that it will eliminate the tendency of certain companies to patronize their executive directors , belonging to the promoter clan by paying abnormal amounts of remuneration regardless of their contribution to the company. Substitution of existing Regulation 17(10) by new regulation - evaluation of Independent Directors The evaluation of Independent Directors shall be done by the entire Board and the evaluation will consider the performance of the Directors as also fulfillment of their criteria of independence as per the regulations and their independence from the Management. In the process of evaluation, the director evaluated shall not participate. Implications: The evaluation process shall undergo a change and will have to factor in the criteria additionally set out above. Insertion of New Regulation 17(11)- Board's recommendation for approval of any special business by shareholders(w.e.f.1.4.2019) The Explanatory Statement for seeking approval of shareholders for any item of special business shall set forth clearly the recommendations of the Board for each such item. Implications: The above change in our view is only of theoretical value since every resolution which is proposed by the Board to the shareholders has to necessarily carry its recommendation. Insertion of New Regulation 17A- Maximum no. of directorships A person shall not be a Director in more than 8 listed companies(W.e.f 1.4.2019) A person shall not be a Director in more than 7 listed companies (w.e.f.1.4.2020) A person shall not be an Independent director in more than 7 listed companies. This restriction already exists in Regulation 25(1) of the SEBI(LODR)Regulations, 2015. WTD/MD in a listed company shall not serve as Independent Director in more than 3 listed companies. Proviso under Regulation 25(1) of the existing Regulations already provides for the above embargo. It is clarified that for the purpose of this sub-clause, a listed entity shall mean only a Company whose equity shares are listed on the stock exchanges. |
W.e.f. 01.04.2019 W.e.f. 01.04.2020 W.e.f. 01.04.2019 W.e.f. 01.04.2020 W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 w.e.f.1.4.2019 |
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Insertion of New Regulation 19(2A) - Nomination & Remuneration Committee - Quorum The present Regulations do not specify a quorum for the above Committee. Hence, the minimum quorum shall be the presence of either two members or 1/3rd of the total strength of the Committee, whichever is greater, subject to the presence of at least one Independent Director. Insertion of New Regulation 19(3A) - Nomination & Remuneration Committee - Minimum no. of Meetings The Committee shall meet at least once a year. As Meetings of the above Committee are need-based , the above stipulation has been proposed. However, it is pertinent to note that the Committee ought to meet at least once a year, given its responsibility under the Statute for carrying out the evaluation of the performance of the directors. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 |
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Regulation 20 - Stakeholders' Relationship Committee The scope of functioning of the Company is being widened to consider various aspects of interest of the security holders. At present the Committee is required to only address grievances of investors. SEBI contemplates that the Committee should have a larger role to play and it has accordingly culled out additional areas of responsibility for the Committee which have been articulated elsewhere in this discussion.. Insertion of New Regulation 20(2A) - Composition of Stakeholders' Relationship Committee. The present Regulations do not contain any provisions relating to composition of the above Committee. As per the amendment, the composition shall be a minimum of three directors with at least one Independent Director. Regulation 20(3) - Presence of Chairman of the Stakeholders' Relationship Committee at the AGM(w.e.f.1.4.2019) The present regulations do not provide for the compulsory presence of the Chairman of the above Committee at the AGM. Such presence will now become necessary. Implication: The above amendment has been proposed to align the Regulations with Section 178(7)of the Act. Insertion of New Regulation 20(3A) - Frequency of Meetings of Stakeholders' Relationship Committee The Committee shall meet at least once a year. Implications: The above proposal is somewhat paradoxical given the responsibility of the Committee to periodically review the redressal of investor grievances. In our view, SEBI should have mandated that the Committee should meet at least twice in an year. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 . W.e.f. 01.04.2019 |
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Insertion of New Regulation 21(3A) - Frequency of Meetings of Risk Management Committee(RMC) The Committee shall meet at least once a year. The periodicity of meetings of the above Committee ought to have been half-yearly ,given that the Committee has to articulate and mitigate business risks which are ever so ambivalent, given the dynamics of the ecosystem. Regulation 21(4) - Terms of reference of RMC Committee should specifically monitor and review cyber security in the company. The Act under Rule 28 of the Companies( Management and Administration)Rules,2014 enjoins upon the Managing Director or the Director responsible for ensuring, inter alia, security of electronic records. The above insert in the Regulations is intended to ensure that there is alignment with the Act as regards cyber security. Regulation 21(5)- Applicability of RMC(w.e.f.1.4.2019) Applicability of RMC shall be extended to top 500 companies determined on the basis of market capitalization instead of 100 at present. The market cap will be determined with reference to the company's financials for the immediately preceding year. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 |
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Regulation 23 - Related Party Transaction(RPT) Regulation 23(1) - Policy on RPT The Board should approve the clear thresholds for RPTs. Policy on RPTs should be reviewed by the Board once in every three years and updated accordingly. Implications: In the light of the above, it would be necessary that the existing company policy on RPTs is reviewed providing for definitive thresholds and the policy shall also be subjected to review once in three years. Insertion of new Regulation 23(1A) - Payments to related parties for brand usage/royalty Where the value of the payment for the above purposes does not exceed 2% of the annual consolidated turnover of the company, the transaction shall not be considered as material and no shareholder approval will be called for. It would be relevant to note that where it comes to determination of materiality of RPTs not belonging to the above genre, the existing threshold of 10% of annual consolidated turnover as provided in the existing Explanation under Regulation 23(1) shall continue since this Explanation has not been deleted. Regulations 23(4) & 23 (7) - Eligibility of Related parties to vote At present related parties cannot vote on any material RPT. Therefore, they have to abstain from voting. This provision is being amended to provide that while related parties shall not vote to approve the transaction, they can either abstain from voting or vote against the transaction. Therefore they cannot have an affirmative vote but can vote against the RPT or abstain from voting. Insert of New Regulation 23(9) - Disclosure of RPT to Stock Exchange Within 30 days from the date of publication of its financial results starting from the half year ending 31.03.2019, the Company shall disclose to the Stock Exchange details of RPTs on a consolidated basis to the stock Exchanges and also publish the same on its website in the format prescribed in the accounting standards. Implication: This is a new requirement which has to be ensured from the half year ending March, 31, 2019. Companies will have to realign themselves with the above requirements effective from half year ending March,31, 2019. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 1.4..2019 w.e.f.half year ending March,31,2019 |
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Governance Requirements relating to Material subsidiary-Amendment to Regulation 24(1) At present it is necessary to appoint on the Board of a “Material unlisted subsidiary' at least one Independent director of the listed company. This requirement is applicable only to a material subsidiary in India. This requirement is being extended to cover an overseas Subsidiary as well. The definition of “material subsidiary' for the purpose of this Regulation shall remain unchanged and it shall mean a Subsidiary whose income or net worth exceeds 20% of the consolidated turnover or net worth of the Company and its subsidiaries in the immediately preceding financial year. Implications- It is important to note that whereas in Regulation 16(1)(c )the definition of "material subsidiary" has been amended to reduce the threshold of income or net worth to 10% from the earlier limit of 20% for the purpose of Regulation 24 above , the threshold will remain unchanged at 20% as in the existing Regulations. |
W.e.f 01.04.2019 |
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Insert of new Regulation 25-Secretarial Audit All listed companies and their material Subsidiaries which are incorporated in India shall be subjected to Secretarial Audit by a practicing Company Secretary and the Report on such audit shall be annexed to the Board's Report. Implications- We would point out that given the revised definition of “material subsidiary' in Regulation 16(1)(c) above, secretarial audit will apply to a subsidiary of a listed company if it is “material' as per the threshold contemplated in Regulation 16 above. Substitution of Regulation 25(1)- No person can be Alternate Director for ID As per existing Regulation, any person can be appointed Alternate Director for an Independent Director for the period of the ID's stay outside India. Such appointment shall not be allowed effective from 01.10.2018 Implications-In our view, this is yet another endeavor to synchronize the Regulations with the amended provisions of the Act.Section 161(2) as amended does not allow the director of the same company to act as an alternate for another director in the same company. Insertion of new Regulation 25(8)-Declaration by Independent Director Every ID shall at the first meeting after his appointment shall provide a declaration as to his independence and also confirm that he is not aware of any circumstances which could impact his ability to discharge his duties by applying his independent judgment and without any external influence. The above declaration has to be provided by the ID at the first Meeting of the Board held in every financial year. The declaration provided has to be taken on record by the Board. Implications-Upon coming into force of the above Regulation , it would be necessary to obtain declarations of independence from directors on the lines indicated above. Insert of Regulation 25(10) - Need for Directors and Officers Insurance (D&O Insurance) for Independent Directors The top 500 companies shall undertake D&O Insurance for all its IDs of such quantum and for such risks to be determined by the Board. Implications: Most listed Companies take out D&O policies for its directors. It may be necessary to revisit the policies and cover such risks as determined by the Board. |
W.e.f. from financial year ending March 31, 2019 w.e.f.1.10.2018 W.e.f. 01.10.2018 |
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(e) Deletion of proviso under Regulation 29 (1) (f)- Proposal for issue of bonus shares As per present regulation, if the proposal for a bonus issue is not part of the Board agenda, there is no need to make a prior intimation to the stock exchanges on the same and it can be considered at the Meeting of the Board. Effective from 01.10.2018, prior intimation for bonus issue will have to be given to stock exchanges and the recommendation should be part of the board agenda. The above change is in the right direction. Some of the listed companies have taken the investors and the markets alike unawares by coming up with bonus announcements without a predetermined agenda , causing unnecessary turbulence in the market. It is appropriate that a bonus announcement is pre-disclosed to the market so that markets are appropriately insulated. |
W.e.f. 01.10.2018 |
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(f) Insert of new Regulation 32(7A) - Disclosure regarding end use of preferential allotment / Qualified Institutional Placement Where funds are raised though the above process, the utilization of such funds has to be disclosed in the Annual Report till the funds are fully utilized. The requirement of providing end-use of details of funds previously applicable to IPOs. The above provision will bring in transparency on end use of security issues of the above genre. |
W.e.f.1.4.2019 |
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Regulation 33 - Amendments regarding disclosure of Financial Results Where the Company has subsidiaries, it has to provide consolidated financial results to the stock exchanges. The option which was available to the company earlier under the Regulations with regard to publication of consolidated financial results , shall no longer be available, thus making publication of consolidated results compulsory. Regulation 33(3)(e) - Limited review for Q4 Results being made compulsory As per existing position, when a company publishes its audited financial results for the year end, the figures for the last quarter of the year are balancing figures, representing the difference between the year-end audited figures and the 9 months figures. It is proposed to make limited review of the figures by the auditors for the last quarter of the year compulsory. The above change is welcome given that the present Regulations provide for disclosure of numbers for the last quarter by way of a differential between the audited numbers and the cumulative numbers for the last three quarters . Making the last quarter numbers subject to a limited review by the auditors adds to their authenticity Insert of new Regulation 33(3)(g) - Requirement of half-yearly cash flow statement along with financial results Provision of statement of half yearly cash flow statement along with consolidated/standalone results being made compulsory. Implications: This proposal will elevate the levels of transparency as far as dissemination of the financial results of the company. Insert of new Regulation 33(3)(h) - Audit/Limited Review to be ensured by company on at least 80% of consolidated revenue, assets and profits Where the company has subsidiaries and publishes consolidated results, it shall ensure that at least 80% of the consolidated revenue, assets and profits are subject to limited review every quarter. By making limited review compulsory to the extent of 80% of the Company's income , the authenticity associated with the consolidated data will be enhanced. Insert of new Regulation 33(3)(i) - Disclosure of aggregate effect of material adjustments in last quarter results In the results of the last quarter of the financial year, company shall disclose by a note the aggregate effect of material adjustments made in the results of that quarter which pertain to earlier periods. The above initiative will lead to avoidance of distortion in the financial data presented. Insert of new Regulation 33(8) - Statutory Auditor to undertake limited review of audit of all companies whose accounts are being consolidated with the company(w.e.f.1.4.2019) The statutory auditor shall carry out a limited review of the Audit of all the companies whose accounts are consolidated in accordance with AS 21 and the guidelines to be issued by SEBI. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 w.e.f.1.4.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 |
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Insert of New Regulation 34(1)in place of existing provision -Dispatch of Annual Report to shareholders As per existing provisions, the Company is required to submit to the Stock Exchange its Annual Report within 21 days from the date of its adoption by the shareholders at the AGM. Changes are being made to the above provision as under:
It is logical that the Stock exchanges should receive the Company's annual Report simultaneously with the shareholders. The requirement to send the Report after the conclusion of the AGM was retrograde in nature. |
With respect to Annual Report for the year ending 31.03.2019 onwards |
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Regulation 36(1)(a) - Dispatch of soft copy of Annual Report to Members At present, soft copy of Annual Report can be sent only to those members whose email ids are registered with the Company for this specific purpose. This provision is being eased to provide that soft copies of the annual report can be sent to those shareholders whose ids are registered with the depositories and with the company. Insert of New Regulation 36(5)in relation to appointment of Statutory Auditors Along with the Notice to the shareholders for the appointment/re-appointment of the statutory auditors, the following additional disclosures are to be provided in the Notice as part of the Explanatory statement:
The above additional disclosure requirements will provide the basis for the rationale of the fee structure to the auditors as also to a better appreciation of the credentials of the Auditors. |
With respect to Annual Report for the year ending 31.03.2019 onwards W.e.f. 01.04.2019 |
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Insert of new Regulations 44 (5) and 44(6) - Timelines for holding AGM and webcast of AGM proceedings
This proposal is out of sync with the provisions of the Act as far as the time lines for holding the AGM is concerned. As regards web casting the issue of operational guidelines will be necessary. |
W.e.f. 01.04.2019 01.04.2019 |
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Regulation 46(2)- Additional information to be disseminated to the shareholders The following additional information shall be provided to the shareholders under a separate section on the company's website:
As changes in rating are so far announced only to the Stock exchanges . the investor at large is unaware of the changes unless he follows the stock closely and keeps himself abreast of corporate announcements. Seeking the provision of such information in the Annual Report is thus appropriate. |
W.e.f. 01.10.2018 W.e.f. 01.04.2019 |
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Amendments in Schedules: Widening the role of Audit Committee Through a new insert in Part C to Schedule II, the Audit committee shall review the utilization of loans/advances/investments made by the holding company in the subsidiary, which exceeds 100 crores or 10% of the asset size of the subsidiary, whichever is lower, including review of existing loans/advances/investments. This proposal is salutary in that there would be better monitoring of funds provided to the subsidiary. Extended role of Nomination & Remuneration Committee The Committee shall additionally recommend to the Board all remuneration payable to Senior Management. Extension in the scope of functioning of the Stakeholders' Relationship Committee Apart from its existing responsibility of addressing grievances of investors, the following additional areas will be considered by the committee:
The Committee will now be in a position to play a pro-active role vis-à-vis the Security holders in the Company. e)Disclosure of Events to the Stock Exchanges without application of guidelines for materiality
The additional disclosures called for as above will make it imperative for the company to come out clean as to the reasons associated with the change in the Auditors and Directors as opposed to coming out with cryptic reasons such as “due to Health reasons' as is usually the case with resignation of directors. If there is a Board room conflict which is simmering, the investor will get forewarned due to the requirements of the above disclosures. Changes in Disclosure of Financial Results
Changes in Disclosure in Annual Report
In case there is a significant change of 25% or more as compared to the previous year, in the following key financial ratios, detailed explanation for such changes are to be provided in the MD&A
or In sector specific equivalent ratios as applicable. Details of any changes in Return on net worth as compared to previous year with explanation. (g) Additional disclosures in Report on “Corporate Governance' 1) With effect from Mach,31,2019, a chart/matrix setting out the skills/expertise/competence of the directors shall be provided providing the list of core skills/expertise/competencies as identified by the Board in the context of the Company's business and those actually available with the Board. 2) With effect from FY ended March 31, 2020, the names of the directors who possess such skills/expertise/competence should be provided in the Report. 3) There shall be a confirmation that ,in the opinion of the Board, the independent directors fulfill the conditions specified in the Regulations and are independent of the Management. 4) In case of resignation of Independent Director during continuance of his tenure, the detailed reasons for the resignation should be provided along with the confirmation by such director that there are no other material reasons for the resignation other than those provided in the Annual Report. 5) Details of all credit ratings obtained by the company along with revisions thereto during the FY for mobilizing funds, both in India or abroad. 6) Details of utilization of funds raised through preferential allotment /qualified institutional placements. 7) A certificate from a practicing company Secretary that none of the directors of the company have been debarred or disqualified from appointment as Director by SEBI/MCA or any other statutory authority. 8) In case the Board has not accepted any recommendation of any committee which is mandatorily required, the details thereof should be provided along with the reasons. 9) Total fees for all services rendered by the statutory auditors to the company and its subsidiaries on a consolidated basis. Conclusion The compliance requirements that will be ushered through the above changes are no doubt going to be arduous and daunting. However, given the objectives associated with the amendments, the changes have to be welcomed as it will elevate the levels of governance which is the paramount need of the day. What is however, discordant is the fact that as elaborated above, many of the changes are not in harmony with the provisions of the Companies Act, 2013.It may not be a bad idea to introspect down the road and develop a separate chapter in the Act on compliance requirements as applicable to listed companies so that the dichotomy between the Regulation and the Act can be put at rest. |
W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 W.e.f. 01.04.2019 With w.e.f from FY ended 31.03.2019 onwards W.e.f. FY ended 31.03.2019 onwards W.e.f. FY ended 31.03.2019 onwards |
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