SEBI Introduces new "Informal Guidance Scheme" – Overview and Key Highlights

 The Capital Market Regulator, the Securities and Exchange Board of India (‘SEBI’), has recently notified the SEBI (Informal Guidance) Scheme, 2025 (‘New Scheme’), replaces the erstwhile SEBI (Informal Guidance) Scheme, 2003 (‘Old Scheme’) with effect from December 1, 2025. The New Scheme seeks to broaden the scope of eligible applicants and streamline the process for obtaining informal guidance, while retaining the core objective of providing regulatory clarity.

Key changes under the New Scheme include the following:

a.      Expanded scope of eligible applicants:
Now, the following players can also seek informal guidance:
– Persons or entities managing investments of registered pooled investment vehicles or acting as their trustees;
– Recognised stock exchanges and clearing corporations; and
– Depositories registered with SEBI.

b.      Centralised and structured mechanism:

– All applications are to be filed electronically through a centralised nodal co-ordination cell at iguidance@sebi.gov.in in the prescribed format.
– Application fees must be paid electronically, with payment confirmation sent to the nodal cell and tad@sebi.gov.in.
– SEBI is required to dispose of applications within 60 days, excluding the time taken by applicants to respond to SEBI’s clarification requests.
– The application fee has been revised to INR 50,000 (earlier INR 25,000). In case of rejection of application, INR 10,000 will be deducted as processing charges.

c.      Confidentiality:

– Applicants may continue to seek confidentiality of guidance for up to 90 days.
– Additionally, applicants may now request redaction of specific facts or commercially sensitive information prior to publication on SEBI’s website, subject to SEBI’s satisfaction.

The New Scheme reflects SEBI’s intent to increase accessibility by expanding the categories of eligible applicants and enhance efficiency by introducing a streamlined process. While the fundamental principles of the Old Scheme remain unchanged under the Scheme, the reforms are expected to improve ease of doing business and to enable various market participants to take more informed and regulatory compliant decisions under the securities laws.