SEBI Consultation Paper on Simplification of Documentation for Transmission of Securities
Date: March 12, 2026
Regulator: Securities and Exchange Board of India (SEBI)
The Securities and Exchange Board of India (SEBI) has issued a consultation paper titled “Ease of investing – Simplification of documentation requirement for transmission of securities and revision in threshold limits for simplified documentation.” The consultation paper proposes amendments to streamline and standardize the process of transmission of securities in the event of the death of an investor.
The objective of the proposal is to reduce documentation complexities, improve ease of settlement for investors’ families, and bring uniformity in procedures followed by listed companies, registrars and transfer agents (RTAs), depositories, depository participants (DPs), and asset management companies (AMCs).
Background
Under the existing framework, procedural requirements for transmission of securities are governed by:
Schedule VII of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 (LODR Regulations)
SEBI Master Circular for Registrars to an Issue and Share Transfer Agents (RTAs)
However, SEBI has received feedback highlighting several challenges in the current system, including:
Complex documentation requirements
Legal hurdles such as obtaining probate or succession certificates
Lack of uniformity in practices across intermediaries
Low monetary thresholds for simplified documentation
Difficulties in obtaining certified death certificates in case of overseas deaths
To address these issues and enhance ease of investing, SEBI has proposed revisions to the existing framework.
Key Proposals
1. Removal of Mandatory Probate Requirement
A significant development influencing the proposal is the removal of mandatory probate under Section 213 of the Indian Succession Act, 1925, effective December 20, 2025.
Earlier, probate of wills was mandatory for certain communities in the erstwhile presidency towns of Mumbai, Chennai, and Kolkata. With the removal of this requirement, probate has now become optional, thereby reducing legal delays and costs associated with transmission claims.
2. Revision of Threshold Limits for Simplified Documentation
SEBI has proposed to revise the current thresholds for simplified documentation as follows:
This measure is intended to reduce cases where the cost of documentation exceeds the value of securities being transmitted.
4. Standardisation of Documentation Requirements
The consultation paper proposes standardized documentation requirements depending on the nature and value of the claim.
Cases where nomination exists
Required documents:
Transmission request form
Latest Client Master List (CML) of the demat account (not older than two months)
Verifiable death certificate
Officially valid identity proof of nominee
Cases with no nomination or will
For simplified cases within threshold limits, the claimant must submit:
Transmission request form
Client Master List (CML)
Death certificate
Identity proof
Notarized indemnity bond
No Objection Certificate (NOC) from legal heirs or family settlement deed
Cases above threshold
Where claims exceed the simplified threshold, documentation may include:
Transmission request form
Client Master List
Death certificate
Identity proof
Notarized affidavit of legal heirs
Along with one of the following:
Succession certificate
Letter of administration
Copy of will along with indemnity bond
Legal heirship certificate with indemnity bond and NOCs
5. Processing Timeline
SEBI has proposed that transmission requests should be processed within 21 calendar days from the date of receipt of all required documents.
In case of delays or rejection, the entity must communicate the reasons to the claimant in writing.
6. Online Submission and Tracking of Claims
Entities may provide an online facility for submission of transmission claims, allowing claimants to:
Upload required documents
Receive acknowledgment
Track claim status online
7. Additional Modes for Verification of Overseas Death Certificates
For investors who pass away outside India, SEBI proposes to accept certification of death documents by:
Authorized officials of overseas branches of scheduled commercial banks registered in India
Authorized officials of foreign banks
This addition aims to simplify cross-border documentation.
Proposed Regulatory Changes
To implement the revised framework, SEBI proposes to:
Delete Para C of Schedule VII of the LODR Regulations
Issue operational provisions through a circular
Amend Regulation 40(7) and Regulation 61(4) of the LODR Regulations
Public Comments
SEBI has invited comments from stakeholders on the consultation paper.
Last date to submit comments: April 2, 2026
Comments may be submitted through the SEBI public comments portal.