SEBI (Portfolio Managers, Custodians, Debenture Trustees, RTAs & CRAs) Compliance Calendar — FY 2026‑27
This calendar consolidates the reporting and certification deadlines for SEBI‑registered Portfolio Managers, Custodians, Debenture Trustees, Registrars & Transfer Agents (RTAs), and Credit Rating Agencies (CRAs) under their respective Master Circulars for FY 2026‑27. It covers monthly custodian reports, quarterly portfolio manager client reports, half‑yearly security cover certificates, internal audit reports, annual fee payments, net‑worth certificates, and periodic filings to SEBI and stock exchanges.
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05 April 2026 (Sunday)
- Monthly report to SEBI (including vault specifications and related operational data) for March 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
07 April 2026 (Tuesday)
- Status of information / breach of covenants or terms of the issue for March 2026, reported latest by 7th of succeeding month. Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
10 April 2026 (Friday)
- Quarterly report to clients (Annexure 5D format) for quarter ending March 2026, within 10 days from end of quarter. Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 5.5.1
30 April 2026 (Thursday)
- Payment of Annual Fee to SEBI (based on assets under custody for previous FY), accompanied by a certified statement of AUC. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter II
05 May 2026 (Tuesday)
- Monthly report to SEBI (including vault specifications and related operational data) for April 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
30 May 2026 (Saturday)
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Certificate of compliance with SEBI (Portfolio Managers) Regulations and circulars, signed by Principal Officer, for FY 2025‑26 (within 60 days of FY end). Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 2.3.1
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Report to SEBI confirming compliance with performance benchmark reporting (firm‑level performance data audited annually) for FY 2025‑26 (within 60 days of FY end). Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 2.4.2
05 June 2026 (Friday)
- Monthly report to SEBI (including vault specifications and related operational data) for May 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
14 June 2026 (Sunday)
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Half‑yearly certificate by statutory auditor certifying security cover and covenant compliance for half‑year ending 31 March 2026 (within 75 days of half‑year end), to be uploaded on the system. Applicability: SEBI‑registered Debenture Trustees (and Issuers of listed debt securities). Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
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Net worth certificate of guarantor, where debt securities are secured by personal guarantee, for half‑year ending 31 March 2026 (within 75 days of half‑year end). Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
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Valuation report and title search report for immovable/movable secured assets (annual, within 75 days of FY end 31 March 2026). Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
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Details of debenture issues handled and their status (Table 4 of Annex‑VIIA) for half‑year ending 31 March 2026 (within 75 days of half‑year end). Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
30 June 2026 (Tuesday)
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Internal Audit report (by independent CA/CS/CMA/CISA) for FY 2025‑26 to be submitted to the Issuer Company (within 3 months of FY end). Applicability: SEBI‑registered Registrars to an Issue and Share Transfer Agents (RTAs). Reference: SEBI Master Circular for RTAs, Section III — Compulsory Internal Audit of RTAs
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Register of records/documents destroyed — to be verified as part of the internal audit process (annual, aligned with internal audit cycle). Applicability: SEBI‑registered Registrars to an Issue and Share Transfer Agents (RTAs). Reference: SEBI Master Circular for RTAs, Section III — Compulsory Internal Audit of RTAs
05 July 2026 (Sunday)
- Monthly report to SEBI (including vault specifications and related operational data) for June 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
10 July 2026 (Friday)
- Quarterly report to clients (Annexure 5D format) for quarter ending June 2026, within 10 days from end of quarter. Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 5.5.1
15 July 2026 (Wednesday)
- Custodian Quarterly Report to SEBI (operational particulars, grievance redressal, investor charter disclosures etc.) — exact day not specified in Master Circular; illustrative mid‑month date. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 6, Annexure O [date inferred, flagged]
31 July 2026 (Friday)
- Half‑yearly Internal Audit report for half‑year ending 30 June 2026, submitted to SEBI — within 2 months of receipt of audit report or 1 month from CRA Board Meeting, whichever is later (illustrative date; actual date floats on receipt/Board meeting). Applicability: SEBI‑registered Credit Rating Agencies (CRAs). Reference: SEBI Master Circular for Credit Rating Agencies, Chapter IV (Internal Audit for CRAs) r.w. Regulation 22, SEBI (CRA) Regulations 1999 [date illustrative, flagged]
05 August 2026 (Wednesday)
- Monthly report to SEBI (including vault specifications and related operational data) for July 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
05 September 2026 (Saturday)
- Monthly report to SEBI (including vault specifications and related operational data) for August 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
30 September 2026 (Wednesday)
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Certificate from a Chartered Accountant certifying net worth as on 31 March 2026 (based on audited accounts, within 6 months of FY end). Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 2.1 (base circular 20‑Mar‑2023)
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Net worth details — certified copy of audited annual accounts/annual report along with net worth certificate signed by a practicing CA (within 6 months of FY close). Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 7
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Annual Review Report of systems, procedures and controls (Regulation 14 of Custodian Regulations) — exact submission day not specified; illustrative, aligned with net worth cert. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 8 [date inferred, flagged]
05 October 2026 (Monday)
- Monthly report to SEBI (including vault specifications and related operational data) for September 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
10 October 2026 (Saturday)
- Quarterly report to clients (Annexure 5D format) for quarter ending September 2026, within 10 days from end of quarter. Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 5.5.1
15 October 2026 (Thursday)
- Custodian Quarterly Report to SEBI (operational particulars, grievance redressal, investor charter disclosures etc.) — exact day not specified in Master Circular; illustrative mid‑month date. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 6, Annexure O [date inferred, flagged]
05 November 2026 (Thursday)
- Monthly report to SEBI (including vault specifications and related operational data) for October 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
05 December 2026 (Saturday)
- Monthly report to SEBI (including vault specifications and related operational data) for November 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
14 December 2026 (Monday)
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Half‑yearly certificate by statutory auditor certifying security cover and covenant compliance for half‑year ending 30 September 2026 (within 75 days of half‑year end). Applicability: SEBI‑registered Debenture Trustees (and Issuers of listed debt securities). Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
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Net worth certificate of guarantor, where debt securities are secured by personal guarantee, for half‑year ending 30 September 2026 (within 75 days of half‑year end). Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
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Details of debenture issues handled and their status (Table 4 of Annex‑VIIA) for half‑year ending 30 September 2026 (within 75 days of half‑year end). Applicability: SEBI‑registered Debenture Trustees. Reference: SEBI Master Circular for Debenture Trustees, Chapter on Periodic Monitoring of Security Cover and Covenants
05 January 2027 (Tuesday)
- Monthly report to SEBI (including vault specifications and related operational data) for December 2026, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
10 January 2027 (Sunday)
- Quarterly report to clients (Annexure 5D format) for quarter ending December 2026, within 10 days from end of quarter. Applicability: SEBI‑registered Portfolio Managers. Reference: SEBI Master Circular for Portfolio Managers dated 07‑Jun‑2024, Para 5.5.1
15 January 2027 (Friday)
- Custodian Quarterly Report to SEBI (operational particulars, grievance redressal, investor charter disclosures etc.) — exact day not specified in Master Circular; illustrative mid‑month date. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 6, Annexure O [date inferred, flagged]
31 January 2027 (Sunday)
- Half‑yearly Internal Audit report for half‑year ending 31 December 2026, submitted to SEBI — within 2 months of receipt of audit report or 1 month from CRA Board Meeting, whichever is later (illustrative date; actual date floats on receipt/Board meeting). Applicability: SEBI‑registered Credit Rating Agencies (CRAs). Reference: SEBI Master Circular for Credit Rating Agencies, Chapter IV (Internal Audit for CRAs) r.w. Regulation 22, SEBI (CRA) Regulations 1999 [date illustrative, flagged]
05 February 2027 (Friday)
- Monthly report to SEBI (including vault specifications and related operational data) for January 2027, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
05 March 2027 (Friday)
- Monthly report to SEBI (including vault specifications and related operational data) for February 2027, by 5th of following month. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Chapter IV, Annexure N
15 April 2027 (Thursday)
- Custodian Quarterly Report to SEBI (operational particulars, grievance redressal, investor charter disclosures etc.) — exact day not specified in Master Circular; illustrative mid‑month date. Applicability: SEBI‑registered Custodians. Reference: SEBI Master Circular for Custodians, Para 6, Annexure O [date inferred, flagged]
How We Help
This calendar spans five distinct SEBI intermediary categories, each with its own reporting rhythm — monthly custodian operational reports, quarterly portfolio manager client reports, half‑yearly debenture trustee security cover certificates, annual internal audits for RTAs and CRAs, and a web of annual certifications for net worth, performance, and systems. At Anuj Desai & Associates, we track every obligation against the specific registration category, prepare the filings and certificates from audited and validated data, and submit them directly to SEBI, depositories, stock exchanges, and trustees. If you would rather not manage this multi‑intermediary compliance grid in‑house, get in touch with our SEBI compliance desk.