๐๐๐๐ฎ๐ซ๐ข๐ญ๐ข๐๐ฌ ๐๐๐ซ๐ค๐๐ญ ๐๐จ๐๐: ๐๐๐ ๐ฌ๐ญ๐ซ๐๐๐ญ’๐ฌ ๐๐จ๐ง๐ญ๐ซ๐ข๐๐ฎ๐ญ๐ข๐จ๐ง ๐ญ๐จ ๐ญ๐ก๐ ๐๐ข๐ฌ๐๐จ๐ฎ๐ซ๐ฌ๐
The Parliamentary Standing Committee on Finance adopted its Report on the Securities Markets Code, 2025 on 21 July 2026 and presented it to the Parliament of India on 23 July 2026.
Regstreet Law Advisors is honoured to have contributed to the policy discourse surrounding this important legislative initiative.
Our Advisers, Dr. M. S. Sahoo (former Whole Time Member, Securities and Exchange Board of India (SEBI) and former Chairperson, Insolvency And Bankruptcy Board Of India) and Shri M Damodaran (former Chairman, Securities and Exchange Board of India (SEBI), UTI and IDBI Bank), deposed before the Standing Committee and shared their perspectives during its deliberations.
Between December 2025 and July 2026, the Partners and Advisers of Regstreet Law Advisors authored twenty-three articles and op-eds on the proposed Securities Markets Code, published across leading national publications, including Business Standard, Financial Express (India), Mint, businessline, and The New Indian Express.
A review of the Standing Committee’s Report reveals a significant convergence between several of the Committee’s recommendations and the issues consistently highlighted in our published work. Among other aspects, the Report recommends:
โข A substantive statutory objective in the Preamble rather than merely recording consolidation.
โข A clearer separation between investigative and adjudicatory functions.
โข Deletion of Clause 93(g), thereby preventing expansion of criminal liability through delegated legislation.
โข Removal of Clause 94 from Schedule II of the PMLA.
โข A merits-based revision mechanism under Clause 21, permitting both enhancement and reduction.
โข Mandatory investor charters and grievance redressal mechanisms.
โข Appealable and time-bound interim orders.
The evolution of India’s securities regulatory framework has benefitted from the contributions of regulators, policymakers, practitioners, industry participants and other stakeholders. Regstreet Law Advisors is privileged to have participated in this process through research and public commentary.
Attached are our detailed note on the Standing Committee’s Report and all twenty-three published articles and op-eds on the Securities Markets Code.
๐๐๐๐ฎ๐ซ๐ข๐ญ๐ข๐๐ฌ ๐๐๐ซ๐ค๐๐ญ ๐๐จ๐๐ :ย ๐๐จ๐ง๐ฏ๐๐ซ๐ ๐๐ง๐๐ ๐จ๐ ๐๐๐ ๐ฌ๐ญ๐ซ๐๐๐ญ’๐ฌ ๐ญ๐ก๐ข๐ง๐ค๐ข๐ง๐ ๐ฐ๐ข๐ญ๐ก ๐ญ๐ก๐๐ญ ๐จ๐ ๐ญ๐ก๐ ๐๐๐ซ๐ฅ๐ข๐๐ฆ๐๐ง๐ญ
The Standing Committee on Finance adopted its Report on the Securities Markets Code, 2025 on 21 July 2026 and presented it to Parliament of India on 23 July 2026.
Two of our Advisers, Dr. M. S. Sahoo, former WTM, SEBI and former Chairperson, Insolvency & Bankruptcy Board of India (IBBI) and Shri M Damodaran, former Chairman of Securities and Exchange Board of India (SEBI), UTI and IDBI Bank, deposed and gave oral evidence before the Committee.
Between December 2025 and July 2026 we published twenty op-eds on the Code in Business Standard, Financial Express (India), Mint, The Hindu businessline and The New Indian Express. Most were jointly authored by the Partners and Advisers of the Firm, while a few were co-authored with other distinguished governance experts.
๐๐๐๐๐ข๐ง๐ ๐ญ๐ก๐ ๐๐๐ฉ๐จ๐ซ๐ญ, ๐ฐ๐ก๐๐ญ ๐ฌ๐ญ๐ซ๐ข๐ค๐๐ฌ ๐ฎ๐ฌ ๐ข๐ฌ ๐ญ๐ก๐ ๐๐จ๐ง๐ฏ๐๐ซ๐ ๐๐ง๐๐. ๐๐ง ๐ข๐ฌ๐ฌ๐ฎ๐ ๐๐๐ญ๐๐ซ ๐ข๐ฌ๐ฌ๐ฎ๐ ๐ข๐ญ ๐ซ๐๐๐๐ก๐๐ฌ ๐๐จ๐ง๐๐ฅ๐ฎ๐ฌ๐ข๐จ๐ง๐ฌ ๐๐ฅ๐จ๐ฌ๐ ๐ญ๐จ ๐ญ๐ก๐จ๐ฌ๐ ๐ฐ๐ ๐๐ซ๐ ๐ฎ๐๐.
The Preamble is to carry a substantive statutory objective, not record consolidation alone. Regulations are to govern the designation and tenure of Investigating and Adjudicating Officers, and an Adjudicating Officer is not to be subordinate to the Investigating Officer in the same matter.Clause 93(g) goes, so criminal liability cannot expand by regulation. Clause 94 comes out of Schedule II to the PMLA. Revision under Clause 21 is to operate on merits, permitting reduction and not only enhancement. The Investor Charter and grievance redressal move from may to shall, and interim orders become appealable and time bound.
Three earlier columns by Sumit Agrawal at Bar and Bench predate the Bill. In December 2024 we set out six provisions the Code ought to contain. Five are now in the Report.
Certain questions remain open. Territorial reach is undefined. Whether a minimum penalty is an absolute floor is unresolved. Regulatory impact assessment carries no mandate. And one conjunction in the market abuse chapter might still catch routine informed trading.
Many stakeholders made submissions; we claim no exclusivity.
๐๐ฎ๐ญ ๐ฐ๐ ๐๐ซ๐ ๐ฉ๐ซ๐จ๐ฎ๐ ๐ญ๐จ ๐ก๐๐ฏ๐ ๐๐จ๐ง๐ญ๐ซ๐ข๐๐ฎ๐ญ๐๐, ๐ข๐ง ๐ฉ๐ซ๐ข๐ง๐ญ ๐๐ง๐ ๐ข๐ง ๐๐ฏ๐ข๐๐๐ง๐๐, ๐ญ๐จ ๐ก๐จ๐ฐ ๐๐ง๐๐ข๐ ๐ฐ๐ซ๐ข๐ญ๐๐ฌ ๐ข๐ญ๐ฌ ๐ฌ๐๐๐ฎ๐ซ๐ข๐ญ๐ข๐๐ฌ ๐ฅ๐๐ฐ. ๐๐ญ๐ญ๐๐๐ก๐๐: ๐จ๐ฎ๐ซ ๐ง๐จ๐ญ๐, ๐๐ง๐ ๐๐ฅ๐ฅ ๐ญ๐ฐ๐๐ง๐ญ๐ฒ-๐ญ๐ก๐ซ๐๐ ๐๐ซ๐ญ๐ข๐๐ฅ๐๐ฌ / ๐๐ฉ-๐๐๐ฌ.
Comments are welcome at info@regstreetlaw.com Regstreet Law Advisors M Damodaran M. S. Sahoo Sumit Agrawal