SME IPO Post Listing Compliance
SME IPO post-listing requirements include filing a reconciliation of share capital, share ratios, financial results, management compensation structure, codes and policies, and more.
SME IPO post-listing requirements include filing a reconciliation of share capital, share ratios, financial results, management compensation structure, codes and policies, and more.
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Planning an SME IPO?
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Once an SME is listed on a stock exchange through an IPO, it becomes subject to a range of ongoing regulatory obligations. These are referred to as post-IPO compliance requirements.
Post-IPO compliance is a critical responsibility for Small and Medium Enterprises (SMEs) that have listed their securities on platforms like BSE SME and NSE Emerge. Upon listing, the SME becomes a publicly accountable entity and must comply with various obligations. These compliances help maintain investor confidence, ensure transparency, and uphold market integrity.
This chapter outlines the comprehensive SME post-IPO compliance framework including quarterly, half-yearly, annual, and event-based requirements.
Post-listing compliances are mainly governed by:
Periodic compliance refers to the regular, time-bound filing and reporting obligations that a listed company must fulfill—such as quarterly, half-yearly, or annual disclosures—under regulatory requirements set by SEBI, BSE, or NSE. These ensure ongoing transparency and governance after listing.
The post-listing compliance requirements for SMEs are outlined in both the BSE SME Compliance Calendar and the NSE Emerge Compliance Calendar. These calendars list:
Companies must refer to the respective exchange's calendar to ensure timely submissions as per their listing venue.
|
Regulation |
Description |
Timeline |
|---|---|---|
|
Reg. 13(3) |
Statement of investor complaints |
Within 21 days (BSE)/30 days (NSE) from end of each quarter* |
|
Reg. 27(2) |
Corporate governance report (Not applicable to SME listings unless thresholds exceeded) |
Within 21 days (BSE)/30 days (NSE) from end of each quarter* |
|
Reg. 76 of SEBI (DP) |
Reconciliation of share capital audit |
Within 30 days from end of each quarter* |
*Quarter: June, September, December, March
|
Regulation |
Description |
Timeline |
|---|---|---|
|
Reg. 7(3) |
Compliance certificate for share transfer facility |
Within 1 month from end of each half year |
|
Reg. 31(1)(b) |
Shareholding pattern (SMEs) |
Within 21 days from end of each half year |
|
Reg. 32(8) |
Statement of deviation or variation in use of IPO proceeds |
Within 45 days from end of H1*, 60 days from end of H2* |
|
Reg. 33(5) |
Financial results (SMEs file half-yearly) |
Within 45 days from end of each half year |
*H1 – September; *H2 -March
|
Regulation |
Description |
Timeline |
|---|---|---|
|
Reg. 33(5) |
Annual financial results (SMEs) |
Within 60 days from end of financial year |
|
Reg. 34(1) |
Annual report and AGM notice |
Not later than date of dispatch to shareholders |
|
Reg. 40(9) |
Practising Company Secretary certificate on share transfers |
Within 30 days from end of financial year |
|
Reg. 30(1), 30(2) of Substantial Acquisition of Shares and Takeovers |
Promoter shareholding disclosure |
Within 7 working days from end of financial year |
|
Regulation |
Event |
Timeline |
|---|---|---|
|
Reg. 7(5) |
Appointment/change of RTA |
Within 7 days of agreement |
|
Reg. 28(1) |
In-principal approval for issuing securities |
Prior to issuance |
|
Reg. 29 |
Board meeting notice |
Financial results: 5 clear days in advance; Other items: 2 working days; Securities changes: 11 working days |
|
Reg. 30(6) |
Disclosure of material events |
Within 24 hours or as applicable |
|
Reg. 31(1)(a), (c) |
Shareholding pattern prior to listing or on capital change >2% |
1 day before listing; within 10 days of change |
|
Reg. 42 |
Record date / book closure |
At least 7 working days in advance (5 days for dividend/bonus) |
|
Reg. 43, 43A |
Declaration of dividend & dividend policy |
Immediately upon declaration (policy required for top 1000 listed entities) |
|
Reg. 44(3) |
Shareholder voting results |
Within 2 working days of conclusion of meeting |
|
Reg. 45(3) |
Change in name of listed entity |
Prior approval required before ROC filing |
|
Reg. 46 |
Company website disclosures |
Updated within 2 working days of any change |
|
Reg. 7(2) of PIT |
Insider trading disclosure |
Within 2 trading days of transaction and notification to exchange |
Maintaining post-IPO compliance incurs several ongoing costs:
These SME IPO post-listing compliance charges are essential for maintaining good standing and avoiding penalties.
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Yes. While SMEs follow basic laws pre-listing—like the Companies Act, Income Tax, GST, labour laws etc—post-IPO compliance becomes more demanding.
Listed SMEs must additionally comply with SEBI (LODR) Regulations, stock exchange norms, and are required to make regular disclosures and maintain transparency with investors. The scope and frequency of filings increase significantly after listing.
Post-listing, SMEs must comply with:
Compliance increases significantly after listing, both in terms of volume and complexity. Key areas include:
Yes. tools and platforms help by:
Missing a compliance deadline attracts monetary penalties from the stock exchange. The amount may vary based on the type and frequency of default, and is typically disclosed publicly by the exchange.
Repeated non-compliance can have more serious consequences. The company may be flagged as non-compliant, placed under the GSM (Graded Surveillance Measure) or ASM (Additional Surveillance Measure) frameworks, and in extreme cases, face suspension of trading in its securities.
Yes. Listed SME companies are required to handle investor grievances as part of their compliance obligations. Under Regulation 13(3) of SEBI (LODR), they must submit a quarterly statement detailing the number of investor complaints received, resolved, and pending.
Beyond reporting, companies must also maintain an effective internal grievance redressal mechanism. This includes appointing a compliance officer, coordinating with the Registrar and Transfer Agent (RTA), and ensuring timely resolution of complaints to uphold investor trust and meet regulatory expectations.
Yes, but these challenges are manageable with the right approach:
Common Challenges:
Ways to Tackle Them:
With early preparation and the right support, compliance becomes a structured and beneficial routine.Top of Form
Integrated filing is a simplified, consolidated compliance mechanism—primarily offered by BSE—where a listed company can fulfil multiple regulatory requirements through a single, unified submission. This reduces the need to make separate filings for each individual regulation.
The goal is to improve efficiency, reduce duplication, and minimize the risk of missed filings. By allowing issuers to comply with various SEBI and exchange requirements in one go, integrated filing supports better compliance management, especially for resource-constrained SME companies.