ICSI Floats Manual on ‘Structured Digital Database (SDD) Compliance Certification’ Under PIT Regulations

The SEBI (Prohibition of Insider Trading) Regulations, 2015 mandate the maintenance of a ‘Structured Digital Database’ (SDD). Under the SDD, it is important for companies to maintain a trail of the sharing of Unpublished Price Sensitive Information (UPSI).

This trail is essential so that if an investigation into breaches of the PIT Regulations or for misuse of UPSI is initiated, then there must be a trail of how the information was shared from one person to another within and outside the company.

CS professionals, being the compliance officers under the PIT Regulations must ensure compliance with policies, procedures, maintenance of records, monitoring adherence to the rules for the preserving UPSI, monitoring of trades, implementing codes, and maintaining the SDD under the PIT Regulations.

In view of this, ICSI has floated a manual on SDD Compliance Certification. The objective is to provide limited guidance on the procedural aspects of maintaining and certifying SDD by professionals.

A “Structured Digital Database” refers to a secured database maintained digitally by a person who is required to handle UPSI under the PIT Regulations. This database contains information about the nature of UPSI, the names of persons who have shared UPSI and with whom such UPSI was shared along with details of their PANs or any other identifier recognized by the law.

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