𝐒𝐞𝐜𝐮𝐫𝐢𝐭𝐢𝐞𝐬 𝐌𝐚𝐫𝐤𝐞𝐭 𝐂𝐨𝐝𝐞: 𝐑𝐞𝐠𝐬𝐭𝐫𝐞𝐞𝐭’𝐬 𝐂𝐨𝐧𝐭𝐫𝐢𝐛𝐮𝐭𝐢𝐨𝐧 𝐭𝐨 𝐭𝐡𝐞 𝐃𝐢𝐬𝐜𝐨𝐮𝐫𝐬𝐞
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:
• A substantive statutory objective in the Preamble rather than merely recording consolidation.
• A clearer separation between investigative and adjudicatory functions.
• Deletion of Clause 93(g), thereby preventing expansion of criminal liability through delegated legislation.
• Removal of Clause 94 from Schedule II of the PMLA.
• A merits-based revision mechanism under Clause 21, permitting both enhancement and reduction.
• Mandatory investor charters and grievance redressal mechanisms.
• 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.
𝐒𝐞𝐜𝐮𝐫𝐢𝐭𝐢𝐞𝐬 𝐌𝐚𝐫𝐤𝐞𝐭 𝐂𝐨𝐝𝐞 : 𝐂𝐨𝐧𝐯𝐞𝐫𝐠𝐞𝐧𝐜𝐞 𝐨𝐟 𝐑𝐞𝐠𝐬𝐭𝐫𝐞𝐞𝐭’𝐬 𝐭𝐡𝐢𝐧𝐤𝐢𝐧𝐠 𝐰𝐢𝐭𝐡 𝐭𝐡𝐚𝐭 𝐨𝐟 𝐭𝐡𝐞 𝐏𝐚𝐫𝐥𝐢𝐚𝐦𝐞𝐧𝐭
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.
𝐑𝐞𝐚𝐝𝐢𝐧𝐠 𝐭𝐡𝐞 𝐑𝐞𝐩𝐨𝐫𝐭, 𝐰𝐡𝐚𝐭 𝐬𝐭𝐫𝐢𝐤𝐞𝐬 𝐮𝐬 𝐢𝐬 𝐭𝐡𝐞 𝐜𝐨𝐧𝐯𝐞𝐫𝐠𝐞𝐧𝐜𝐞. 𝐎𝐧 𝐢𝐬𝐬𝐮𝐞 𝐚𝐟𝐭𝐞𝐫 𝐢𝐬𝐬𝐮𝐞 𝐢𝐭 𝐫𝐞𝐚𝐜𝐡𝐞𝐬 𝐜𝐨𝐧𝐜𝐥𝐮𝐬𝐢𝐨𝐧𝐬 𝐜𝐥𝐨𝐬𝐞 𝐭𝐨 𝐭𝐡𝐨𝐬𝐞 𝐰𝐞 𝐚𝐫𝐠𝐮𝐞𝐝.
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.
𝐁𝐮𝐭 𝐰𝐞 𝐚𝐫𝐞 𝐩𝐫𝐨𝐮𝐝 𝐭𝐨 𝐡𝐚𝐯𝐞 𝐜𝐨𝐧𝐭𝐫𝐢𝐛𝐮𝐭𝐞𝐝, 𝐢𝐧 𝐩𝐫𝐢𝐧𝐭 𝐚𝐧𝐝 𝐢𝐧 𝐞𝐯𝐢𝐝𝐞𝐧𝐜𝐞, 𝐭𝐨 𝐡𝐨𝐰 𝐈𝐧𝐝𝐢𝐚 𝐰𝐫𝐢𝐭𝐞𝐬 𝐢𝐭𝐬 𝐬𝐞𝐜𝐮𝐫𝐢𝐭𝐢𝐞𝐬 𝐥𝐚𝐰. 𝐀𝐭𝐭𝐚𝐜𝐡𝐞𝐝: 𝐨𝐮𝐫 𝐧𝐨𝐭𝐞, 𝐚𝐧𝐝 𝐚𝐥𝐥 𝐭𝐰𝐞𝐧𝐭𝐲-𝐭𝐡𝐫𝐞𝐞 𝐚𝐫𝐭𝐢𝐜𝐥𝐞𝐬 / 𝐎𝐩-𝐄𝐝𝐬.
Comments are welcome at info@regstreetlaw.com Regstreet Law Advisors M Damodaran M. S. Sahoo Sumit Agrawal