SEBI17 min read

UPSI

Acronyms / Synonyms:UPSIUnpublished Price Sensitive Information

Last updated: 16 May 2026

Quick Summary (TL;DR)🔗

•SEBI’s 2025 PIT amendment expanded UPSI from 5 to 16 illustrative categories.
•New UPSI categories now include items like fraud, default, arrest, forensic audit, loan restructuring, CIRP, fundraising, and major litigation outcomes.
•UPSI is still based on being non-public and price-sensitive, so the list is not exhaustive.
•For UPSI coming from outside the company, trading window closure is not automatically required just because the information is external.
•External UPSI still needs careful compliance review, SDD recording, and documentation by the compliance officer.
•Companies should update their insider trading policy, SDD process, designated persons list, and trading window rules.
•The 2025 changes make insider-trading compliance more practical, but also more judgment-based.

Every listed company director, promoter, compliance officer and employee who has access to company information needs to understand one concept above everything else in securities law: UPSI (Unpublished Price Sensitive Information). Trading in a company’s shares while in possession of UPSI is the core insider trading risk under the PIT Regulations, and SEBI enforces it seriously. In the most significant reform since 2015, SEBI amended the UPSI framework through a notification dated 11 March 2025, effective 10 June 2025, expanding the illustrative UPSI list from 5 to 16 categories and introducing important compliance changes for listed companies.

🚨 Amendment at a Glance

Notification Date

11 Mar 2025

Effective Date

10 Jun 2025

UPSI Events

5 → 16

Notification No. SEBI/LAD-NRO/GN/2025/235 | SEBI Board Approved: 18 December 2024 (208th Board Meeting)

📖 Section 1 — What is UPSI? The Foundation

UPSI — Unpublished Price Sensitive Information is defined under Regulation 2(1)(n) of the SEBI (Prohibition of Insider Trading) Regulations, 2015 as:

📜 Official Definition — Regulation 2(1)(n)

"Any information, relating to a company or its securities, directly or indirectly, that is not generally available which upon becoming generally available, is likely to materially affect the price of the securities and shall, ordinarily including but not restricted to, information relating to..."

— followed by the illustrative list of events (now expanded to 16)

Breaking this definition down into its three essential elements:

🔒

Element 1 — NOT GENERALLY AVAILABLE

The information has not been made public — not on stock exchange, not in any public announcement

📈

Element 2 — PRICE SENSITIVE

Once it becomes public, it is LIKELY to materially affect the price of the company's securities

🏢

Element 3 — RELATES TO COMPANY

Directly or indirectly relates to the company or its securities

💡 Plain English Explanation

Imagine a company director knows its quarterly results are going to be terrible — far below expectations — but this has not been announced yet. If the director sells his shares NOW before the announcement, he benefits because other investors don't know what he knows. That is insider trading. The non-public bad results are the UPSI. Trading on it is the crime.

📜 Section 2 — History and Journey of UPSI Law in India

1992

First Insider Trading Regulations — SEBI Act passed

SEBI (Insider Trading) Regulations, 1992 first introduced

2015

Comprehensive Overhaul — PIT Regulations 2015

N.K. Sodhi Committee recommended comprehensive revision. SEBI (Prohibition of Insider Trading) Regulations, 2015 notified. UPSI defined with 5 illustrative categories under Regulation 2(1)(n).

August 2018

Committee on Fair Market Conduct (FMC Committee) Report

Recommended removing "material events in accordance with listing agreement" from UPSI definition. Noted that not all LODR disclosures are price-sensitive.

18 May 2023

SEBI Consultation Paper 1 — Proposed aligning UPSI with LODR Regulation 30

Proposed including ALL material events under Regulation 30 as UPSI. Industry pushed back — too broad.

9 November 2024

SEBI Consultation Paper 2 — Refined proposal

Narrowed to include only price-sensitive events from Schedule III. Excluded ESG ratings, routine operational disclosures.

18 December 2024

SEBI Board Approves Amendment — 208th Board Meeting

SEBI Board approved expanded UPSI definition. Also approved flexibility for external UPSI.

11 March 2025

Amendment Notified — Notification No. SEBI/LAD-NRO/GN/2025/235

Published in Official Gazette on 12 March 2025. To come into force 90 days later.

10 June 2025 — EFFECTIVE DATE ✅

Illustrative UPSI list expanded from 5 to 16 categories — now in force

All listed companies must comply with expanded UPSI definition, new SDD timelines and revised trading window rules from this date.

📋 Section 3 — The Complete UPSI List: Old vs New

Before the June 2025 amendment, Regulation 2(1)(n) listed only 5 illustrative events as UPSI. The amendment adds sub-clauses vi to xvi, taking the illustrative list to 16 categories. Here is the complete current list.

Existing Events (Modified — Sub-clauses i to v)

Sub-clause	UPSI Event	What It Covers	Change in 2025
(i)	Financial Results	Quarterly/annual P&L, revenue, profit/loss figures before announcement to exchange	No change
(ii)	Dividends	Declaration of interim or final dividend before board announcement	No change
(iii)	Change in Capital Structure	Rights issue, bonus shares, buyback, preferential allotment — before announcement	No change
(iv)	Mergers, Demergers, Acquisitions, Delistings + Orders/Contracts	M&A activity, corporate restructuring; now also includes: award or termination of orders/contracts not in the normal course of business	Modified — expanded
(v)	Changes in Key Managerial Personnel	Changes in MD/CEO/CFO/CS and other KMPs; now also includes resignation of Statutory Auditor or Secretarial Auditor; excludes changes due to superannuation, term completion, or routine auditor resignation	Modified — expanded + exclusions added

New Events Added — Sub-clauses (vi) to (xvi) [Effective 10 June 2025]

Sub-clause	New UPSI Event	What It Means in Practice	Source in LODR
(vi)	Change in Credit Ratings	Any upward or downward revision in credit rating by a rating agency. ESG ratings are specifically excluded. Applies to debt instruments, bank facilities etc.	Para A, Sch. III, LODR
(vii)	Fundraising Activities	Any proposed fundraising — equity, debt, convertibles — when the decision is made internally before public announcement. Includes QIP, private placement, NCD issuance etc.	Para A, Sch. III, LODR
(viii)	Agreements Impacting Management or Control	Any agreement — regardless of what it is called — that impacts management, ownership, or control of the company. Examples: shareholder agreements, promoter lock-in agreements, voting rights agreements.	Para A, Sch. III, LODR
(ix)	Fraud, Defaults, or Arrests	Any fraud, default, or arrest of the company, its promoters, directors, KMPs, or subsidiary — whether in India or abroad. This is a major new category. Fraud = as defined under SEBI PFUTP Regulations, 2003. Default = as defined under LODR.	Para A, Sch. III, LODR
(x)	Loan Restructuring / One-Time Settlement	Any loan restructuring, resolution plan, or one-time settlement (OTS) entered into with banks/financial institutions. Captures financially distressed situations before public announcement.	Para A, Sch. III, LODR
(xi)	Insolvency / Winding Up / CIRP	Admission of a winding-up petition or CIRP (Corporate Insolvency Resolution Process) application under IBC, including approval or rejection of such petition/application.	Para A, Sch. III, LODR
(xii)	Forensic Audit	Both the initiation of a forensic audit AND the receipt of the final forensic audit report are now UPSI. Forensic audits are conducted to investigate financial irregularities.	Para A, Sch. III, LODR
(xiii)	Regulatory / Enforcement Actions	Significant fines/penalties imposed on the company: fines exceeding ₹1 lakh imposed by sector regulators/enforcement agencies; fines exceeding ₹10 lakhs by other authorities.	Para B, Sch. III, LODR
(xiv)	Acquisition / Disposal of Significant Stake	Acquisition or disposal of a subsidiary, associate, or joint venture — or stake sale — that is material per LODR guidelines.	Para B, Sch. III, LODR
(xv)	Significant Litigation Outcomes	Outcome of significant court/tribunal orders or proceedings that are likely to materially affect the company's operations, financials or reputation.	Para B, Sch. III, LODR
(xvi)	Other Material Events (Residual)	Any other event/information as specified by SEBI or as per materiality criteria in LODR that is likely to materially affect the price of securities.	Para B, Sch. III, LODR

⚠️ Important Note on the List

Why this matters

SEBI did not convert every Regulation 30 disclosure into UPSI. The final amendment selected categories that are ordinarily price-sensitive and left out several routine or lower-impact disclosures. This means compliance teams must still apply judgment rather than mechanically treating every disclosure as UPSI.

The UPSI list is illustrative — not exhaustive. The definition uses "shall ordinarily include but not restricted to." This means ANY information satisfying the three core elements (non-public + price-sensitive + relates to company) can be UPSI — even if not in the list. The list merely tells you which events are presumed to be UPSI. For Para A events, no materiality test applies. For Para B events, materiality must be assessed per LODR guidelines.

🔄 Section 4 — Two Other Key Changes in the 2025 Amendment

Change 1 Trading Window Closure Relief for Externally Originating UPSI

One of the most practically significant changes is the relaxation of trading window closure requirements for UPSI originating from outside the listed company. This change is made through a proviso added to Clause 4(1) of Schedule B to the PIT Regulations.

❌ OLD RULE

Trading window MUST be closed whenever designated persons are in possession of ANY UPSI — regardless of whether it came from inside or outside the company.

✅ NEW RULE (from 10 Jun 2025)

For UPSI that originates from outside the listed entity, trading window closure is not mandatorily required merely for that reason. The Compliance Officer should still assess the facts, internal controls, and whether any restriction is appropriate in the circumstances.

💡 What is "External UPSI"? Example

A rating agency informs the company that it is downgrading its credit rating before the formal announcement. This information comes from an external party — the rating agency — but relates to the company. Under the amended framework, the Compliance Officer may record it in the SDD within 2 calendar days, and trading window closure is not automatically required merely because the UPSI originated externally. A documented factual assessment is still advisable.

Change 2 — SDD Entry: 2-Day Window for External UPSI

The Structured Digital Database (SDD) is the record-keeping system every listed entity must maintain under Regulation 3(5) of the PIT Regulations — recording all persons who share/receive UPSI, with timestamps. A new proviso to Regulation 3(5) gives companies flexibility for externally-originating UPSI:

SDD Entry Requirement	Internal UPSI (from within company)	External UPSI (from outside company)
When to enter in SDD	Immediately / as soon as shared	Within 2 calendar days of receipt
Trading window closure	Mandatory	Not automatically required merely because the UPSI originated externally
SDD entry required?	Yes — always	Yes — but within 2 days

Compliance takeaway

The 2025 amendment creates operational flexibility, but not a free pass. Compliance teams should document (i) whether the UPSI originated internally or externally, (ii) when it was first received, (iii) when it was entered into the SDD, and (iv) why trading window closure was or was not considered necessary on the facts.

👥 Section 5 — Who is an "Insider" and Who are "Designated Persons"?

UPSI is only relevant if you are an "insider" — because only insiders are prohibited from trading on UPSI.

Who is an Insider? — Regulation 2(1)(g)

An insider is any person who is a connected person or any person in possession of or having access to UPSI. This includes:

Directors and officers of the company
Employees of the company
Auditors, accountants, lawyers, bankers of the company
Any person who receives UPSI from any of the above
Promoters and their immediate relatives

Who are "Designated Persons"?

Designated Persons (DPs) are the specific group of employees and connected persons on whom trading window restrictions apply. Every listed company must maintain a list of Designated Persons — typically including:

Typically Always Designated:

Board of Directors
MD / CEO / CFO / CS (KMPs)
All Senior Management
Accounts/Finance team
Legal and Compliance team

May Also Include:

Immediate relatives of above persons
Promoters and promoter group
Auditors, bankers, legal advisors
Business development/M&A team
Any employee with access to UPSI

🚫 Section 6 — What is Prohibited? The Insider Trading Offences

The PIT Regulations prohibit three specific activities when you are in possession of UPSI:

#	Prohibited Activity	Regulation	Example
1	Trading in securities while in possession of UPSI	Reg. 4(1)	Director sells shares before bad quarterly results are announced
2	Communicating / tipping UPSI to another person	Reg. 3(1)	CFO tells broker friend about upcoming merger before announcement — broker then trades
3	Procuring or counselling another person to deal in securities while in possession of UPSI	Reg. 3(2)	Company promoter advises relative to buy shares just before positive announcement

⚠️ The "Possession vs Knowledge" Trap

A critical aspect of insider trading law is that it is based on possession of UPSI — not necessarily conscious knowledge that you possess it. If you are a designated person and UPSI exists about your company, you may not trade — even if you personally did not receive a specific briefing. The defense that "I didn't know about it" is very difficult to establish. This is why trading windows exist — they create a safe period when all UPSI has been published and the slate is clean.

🪟 Section 7 — The Trading Window: What It Is and How It Works

The Trading Window is a concept under Schedule B to the PIT Regulations. It is a period during which designated persons are allowed to trade in the company's securities. When the window is "closed," trading is prohibited.

When Must the Trading Window Be Closed?

When the company is preparing quarterly/annual financial results — typically closed 48 hours before board meeting
When UPSI originating from within the company exists and has not been published
During M&A transactions, fundraising, restructuring — any internal UPSI event
From 10 June 2025 — where UPSI originates from outside the company, trading window closure is not mandatorily required merely for that reason; the Compliance Officer should still assess the facts and the company’s internal controls.

Typical Trading Window Calendar for Listed Companies

Quarter	Window Closes	Window Opens After
Q1 (Apr-Jun)	~24-48 hrs before Q1 results board meeting (around July)	48 hours after Q1 results published on stock exchange
Q2 (Jul-Sep)	~24-48 hrs before Q2 results board meeting (around October)	48 hours after Q2 results published
Q3 (Oct-Dec)	~24-48 hrs before Q3 results board meeting (around January)	48 hours after Q3 results published
Q4 / Annual (Jan-Mar)	~24-48 hrs before Annual results board meeting (around May)	48 hours after Annual results published

Section 8 Recognised Safe Situations and Common Defences in Insider Trading Cases

The PIT framework recognises certain permitted situations, structured safe routes such as trading plans, and practical defence arguments depending on facts, records, and timing. The three situations below are the most exam-relevant and compliance-relevant.

DEFENSE 1

Trading Plans — Regulation 5

A designated person who expects to be perpetually in possession of UPSI can pre-commit to a fixed trading plan through the compliance officer. The plan specifies in advance when, how many shares, and at what price/price range they will trade. Once the plan is submitted and a cooling-off period passes, trades under the plan are permitted even if UPSI exists. Trading plans were made more flexible effective November 1, 2024 — the cooling-off period was reduced.

DEFENSE 2

Chinese Wall / Off-Wall Trading

Where a company has established information barriers (Chinese walls) — so that one division of the company does not share UPSI with another — persons in the division without access to UPSI can trade. This applies mainly to financial intermediaries.

DEFENSE 3

UPSI Already in Public Domain

If the information has already been made generally available to the public — published on stock exchange, in a press release, or in the public domain through reliable channels — it is no longer UPSI. Trading after this point is permitted.

⚠️ Section 9 — Penalties for Insider Trading in India

Provision	Penalty
Civil Penalty — Section 15G, SEBI Act	Up to ₹25 crore OR 3 times the amount of profit made or loss avoided — whichever is higher
Criminal Prosecution — Section 24, SEBI Act	Imprisonment up to 10 years AND/OR fine up to ₹25 crore
Disgorgement of Profits	SEBI can order disgorgement of all profits from insider trading
Debarment	Individual can be debarred from accessing securities market
Failure to maintain SDD — Compliance Officer	Separate penalty on Compliance Officer personally

🚨 SEBI Enforcement is Serious

SEBI has consistently and aggressively enforced insider trading regulations. In the landmark case of SEBI v. Cabot International Capital Corporation, the Bombay High Court clarified that penalties under the SEBI Act are civil in nature — meaning mens rea (guilty mind) does not need to be proven. Mere possession of UPSI and trading during that period is sufficient for penalty — intent is irrelevant.

💼 Section 10 — Compliance Officer's Action Checklist Post June 2025

✅ What Every Compliance Officer Must Do Now

Update the Code of Conduct — Revise your company's Code of Fair Disclosure and Code of Conduct to reflect the expanded 16-event UPSI definition
Retrain Designated Persons — Conduct training/awareness sessions explaining the new categories of UPSI including fraud/default/arrest, forensic audit, rating changes
Update the Designated Persons list — Review and update who is on the DP list given expanded UPSI triggers
Revise SDD procedures — Update SDD entry protocols: immediate entry for internal UPSI, 2-calendar-day window for external UPSI
Identify internal vs external UPSI — Build an internal classification mechanism to distinguish internal from external UPSI — this determines trading window closure obligation
Update Trading Window Policy Clearly document that externally originating UPSI does not automatically trigger trading window closure merely for that reason, and that the Compliance Officer must record the basis of the assessment made.
Align with LODR Regulation 30 materiality standards — For Para B events, ensure materiality is assessed per LODR Schedule III and Industry Standards dated 25 February 2025
Board communication — Ensure the board is informed about expanded insider trading exposure — especially on fraud/default/arrest category
Audit the existing SDD — Review historical SDD entries to identify any gaps in the context of now-expanded UPSI definition

Practical caution

The amendment does not eliminate judgment calls. A strong compliance file should record the basis on which a particular event was classified as UPSI, whether it was linked to Schedule III of LODR, and what internal controls were triggered in response.

📜 Section 11 — Key Legal Provisions Reference

Provision	What It Says
Regulation 2(1)(n) — PIT Regulations	Definition of UPSI — now 16 events (sub-clauses i to xvi) effective 10 June 2025
Regulation 2(1)(g) — PIT Regulations	Definition of "Insider" — includes connected persons and any person with access to UPSI
Regulation 3 — PIT Regulations	Communication of UPSI prohibited; SDD maintenance obligation (Reg 3(5)); new 2-day proviso for external UPSI
Regulation 4 — PIT Regulations	Trading while in possession of UPSI prohibited
Regulation 5 — PIT Regulations	Trading Plan — legitimate defense for persons perpetually in possession of UPSI
Schedule B, Clause 4(1) — PIT Regulations	Trading Window provisions; under the new proviso, externally originating UPSI does not by itself make trading window closure automatically mandatory, subject to factual assessment by the Compliance Officer
Regulation 30 + Schedule III — LODR	Material events that listed companies must disclose; now aligned with UPSI definition for Para A and Para B events
Section 15G — SEBI Act, 1992	Civil penalty for insider trading — up to ₹25 crore or 3x profit, whichever higher
Section 24 — SEBI Act, 1992	Criminal prosecution — imprisonment up to 10 years and/or fine up to ₹25 crore

📝 Bottom Line — UPSI in 2026: What You Must Know

✅UPSI list expanded from 5 to 16 illustrative categories Effective 10 June 2025, major new categories include rating changes, fraud/arrest/default, forensic audits, CIRP or winding-up proceedings, fundraising and loan restructuring.

✅External UPSI brings compliance relief, not automatic exemption If UPSI originates from outside the company, trading window closure is not mandatorily required merely for that reason, though SDD entry within 2 calendar days and a documented factual assessment remain important.

✅Materiality aligned with LODR: For identifying whether a Para B event is UPSI, the materiality criteria under Schedule III of LODR Regulation 30 and Industry Standards dated 25 February 2025 apply.

✅ Compliance Officer accountability: With a broader UPSI definition, the compliance officer's role has never been more critical. Update codes, retrain DPs, revise SDD procedures — immediately.

✅Intent is not the main test In insider trading matters, SEBI focuses heavily on possession of UPSI and the surrounding facts rather than proving guilty intent in the criminal-law sense. A defence based merely on lack of awareness is usually difficult unless backed by credible evidence.

Sources: SEBI (Prohibition of Insider Trading) Regulations, 2015 as amended | SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2025 — Notification No. SEBI/LAD-NRO/GN/2025/235 dated 11 March 2025, effective 10 June 2025 | SEBI Board Meeting Minutes — 208th Board Meeting dated 18 December 2024 | SEBI Consultation Papers dated 18 May 2023 and 9 November 2024 | Industry Standards on Regulation 30 of SEBI LODR dated 25 February 2025 | SEBI (LODR) Regulations, 2015 — Regulation 30 and Schedule III | SEBI Act, 1992 — Sections 15G and 24 | sebi.gov.in.

⚠️ Disclaimer: This article is for educational and informational purposes only. It does not constitute legal advice. Readers should consult qualified legal professionals for specific compliance guidance.

Frequently Asked Questions (FAQs)🔗

Q1. 1. What is UPSI?▼

UPSI means unpublished price sensitive information — information that is not generally available and, if published, is likely to materially affect a company’s securities price.

Q2. 2. What does UPSI stand for?▼

UPSI stands for Unpublished Price Sensitive Information.

Q3. 3. What is the legal definition of UPSI in India?▼

Under the PIT Regulations, UPSI is information relating to a company or its securities that is not generally available and is likely to materially affect the price of the securities.

Q4. 4. How many UPSI categories are there after the 2025 amendment?▼

After the 2025 amendment, the illustrative UPSI list expanded from 5 to 16 categories.

Q5. 5. Is the UPSI list exhaustive?▼

No. The list is illustrative, not exhaustive, so other non-public price-sensitive information can still qualify as UPSI.

Q6. 6. When did the 2025 UPSI amendment become effective?▼

The amendment became effective on 10 June 2025.

Q7. 7. What are the new UPSI categories added in 2025?▼

The 2025 amendment added categories such as fundraising, agreements affecting management or control, forensic audit, fraud, defaults, arrests, loan restructuring, insolvency-related matters, regulatory enforcement actions, and significant litigation outcomes.

Q8. 8. Is every Regulation 30 disclosure automatically UPSI?▼

No. Only disclosures that are price-sensitive in nature and fit the UPSI framework should be treated as UPSI.

Q9. 9. Does materiality matter for UPSI?▼

Yes. For the new UPSI categories, materiality is assessed using the LODR materiality framework and Schedule III principles.

Q10. 10. What is external UPSI?▼

External UPSI is information that originates outside the listed company but still relates to the company and may affect its share price.

Q11. 11. Does external UPSI require mandatory trading window closure?▼

Not automatically. The 2025 amendment gives relief from mandatory closure merely because the UPSI came from outside the company, but the compliance officer should still assess the facts.

Q12. 12. How quickly must external UPSI be entered into the Structured Digital Database?▼

It may be entered within 2 calendar days of receipt.

Q13. 13. Does internal UPSI still require immediate SDD entry?▼

Yes. UPSI originating within the company should be recorded immediately under normal compliance practice.

Q14. 14. What is the Structured Digital Database?▼

The Structured Digital Database is the prescribed record of persons who share or receive UPSI, along with timestamps and related details.

Q15. 15. Who is an insider under PIT Regulations?▼

An insider includes a connected person or anyone in possession of or having access to UPSI.

Q16. 16. Who are designated persons?▼

Designated persons are employees and connected persons identified by the company for trading window and compliance control purposes.

Q17. 17. Can a person trade if they did not know the information was UPSI?▼

That defense is difficult to sustain in practice because insider trading law focuses heavily on possession of UPSI and the surrounding facts.

Q18. 18. What is insider trading?▼

Insider trading is trading in securities while in possession of UPSI, or communicating or counseling another person to trade on that basis.

Q19. 19. What activities are prohibited under PIT?▼

The PIT Regulations prohibit trading while in possession of UPSI, communicating UPSI, and procuring or counseling another person to trade on UPSI.

Q20. 20. What is the trading window?▼

The trading window is the period when designated persons are permitted to trade in the company’s securities, subject to compliance controls.

Q21. 21. When is the trading window usually closed?▼

It is commonly closed around financial results, internal UPSI events, mergers, fundraising, and other sensitive corporate actions.

Q22. 22. Does the 2025 amendment change the trading window rule?▼

Yes. For UPSI originating outside the company, trading window closure is not automatically mandatory merely for that reason.

Q23. 23. What is a trading plan under PIT?▼

A trading plan lets a designated person pre-commit to trades in advance, subject to prescribed conditions and cooling-off rules.

Q24. 24. Are trading plans always allowed?▼

They are allowed only if the PIT conditions are met, including proper advance filing and compliance with the cooling-off period.

Q25. 25. What is the penalty for insider trading in India?▼

Penalties can include monetary penalties, disgorgement of profits, debarment from the securities market, and in serious cases criminal prosecution under the SEBI Act.

Q26. 26. Can SEBI punish a person even without proof of intent?▼

Yes. Insider trading enforcement is heavily possession-based, so proving guilty intent is not always necessary for penalty.

Q27. 27. Why is the 2025 amendment important?▼

It broadens the UPSI framework, reduces ambiguity, and creates more practical compliance rules for externally sourced information.

Q28. 28. Should companies revise their insider trading policy after the amendment?▼

Yes. Companies should update their code of conduct, SDD process, trading window policy, and DP list to reflect the new rules.

Q29. 29. Does every external event mean the trading window can remain open?▼

No. The company must still evaluate the facts, internal controls, and whether any restriction is needed.

Q30. 30. What is the safest compliance approach for companies?▼

The safest approach is to classify information carefully, record it promptly in the SDD, document the basis for trading window decisions, and train designated persons regularly.

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