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SEBI / Research Analysts

Proxy Adviser – Periodic Reporting Format and Direct Submission to SEBI

A comprehensive guide on the periodic reporting format for proxy advisers and direct submission to SEBI.

25 Jul 20264 min read

Proxy Advisers (PAs) must submit periodic reports to SEBI in a specific format. This report covers key information about the PA's operations, complaints, and activities. This article provides a comprehensive technical analysis of the periodic reporting format and submission process.

Regulatory Basis

Periodic Reporting Circular

The circular dated October 25, 2024 (SEBI/HO/MIRSD/MIRSD-PoD1/P/CIR/2024/148) specifies:

"Proxy advisers shall submit the periodic report in a format provided at Annexure J."

Reporting Periods

Half-Yearly Periods

PeriodDates
Half-Year 1April 1 to September 30
Half-Year 2October 1 to March 31

Reporting Deadlines

PeriodReporting Deadline
September 30October 30
March 31April 30

Annexure J – Periodic Reporting Format

1. Identification Information

InformationRequired
Registered Name (as per SEBI certificate)Yes
Trade Name/Brand NameYes
Permanent Account Number (PAN)Yes
SEBI Registration No.Yes
Logo (if any)Yes/No
Date of Incorporation/BirthYes
Legal StructureYes

2. Address and Branch Details

InformationRequired
Registered Office AddressYes
Correspondence AddressYes
Principal Place of BusinessYes
Number of BranchesYes
Addresses of BranchesYes

3. Personnel Details

InformationRequired
Total Number of EmployeesYes
Contact Person DetailsYes
Compliance Officer DetailsYes
Managing Director/Partner DetailsYes
Other Directors/PartnersYes

4. Shareholding Details

InformationRequired
Shareholder NameYes
Number of SharesYes
% of ShareholdingYes

5. Bank Account Details

InformationRequired
Bank Account NameYes
Account NumberYes
Type of AccountYes
IFSC CodeYes
Bank NameYes
Bank Branch NameYes

6. Compliance Information

InformationRequired
Inspection DetailsYes
Number of Advertisements IssuedYes
Complaints Pending/Received/ResolvedYes

7. Activity Information

InformationRequired
Number of Agenda ItemsYes
Number of Reports for General MeetingsYes
Number of Other ReportsYes
Number of Clients/SubscribersYes
Total Amount of Fees ReceivedYes

Submission Process

Step 1: Prepare the Report

  • Collect all required information
  • Complete the report in Annexure J format

Step 2: Review the Report

  • Review for accuracy and completeness
  • Verify all data

Step 3: Submit to SEBI

  • Submit directly to SEBI
  • Follow the prescribed submission process

Step 4: Retain Records

  • Retain a copy of the report
  • Maintain for five years

Common Compliance Gaps

1. Not Submitting

Some PAs do not submit the periodic report.

Solution: Submit the report on time.

2. Incomplete Report

Some PAs submit incomplete reports.

Solution: Ensure all sections are completed.

3. Incorrect Data

Some PAs submit incorrect data.

Solution: Verify all data before submission.

4. Missing the Deadline

Some PAs miss the reporting deadline.

Solution: Submit the report on time.

Consequences of Non-Compliance

1. Regulatory Action

SEBI may take action for non-compliance.

2. Monetary Penalties

SEBI may impose monetary penalties.

3. Reputational Damage

Non-compliance can damage the PA's reputation.

Conclusion and How Anuj Desai & Associates Can Help

Periodic reporting is a critical compliance requirement for PAs.

Anuj Desai & Associates offers specialized services to help PAs comply with periodic reporting requirements:

  • Report preparation
  • Data verification
  • Submission assistance
  • Compliance audit and advisory

Contact us today to ensure your periodic reports comply with SEBI requirements. Our team will guide you through the process.


Disclaimer: This article is for informational purposes only and does not constitute legal advice. Readers are advised to consult qualified professionals for legal and compliance matters. Anuj Desai & Associates is a SEBI compliance consulting firm based in India.


Compliance Guideproxy adviser periodic reportingPA reporting formatPA direct submission SEBIPA periodic reportAnnexure J PAPA reporting requirementsPA compliance reportingPA half-yearly reportingAnuj Desai and AssociatesSEBI compliance consultantPA compliance expert
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