Issued by SEBI (Market Intermediaries Regulation and Supervision Department) on July 23, 2026. Revised transmission framework and model forms come into force 30 days from issuance, i.e., on or about August 22, 2026.
Transmission of securities — the process of transferring a deceased investor's holdings to nominees or legal heirs — has long been flagged by investors and intermediaries as slow, paperwork-heavy, and inconsistent across listed companies, RTAs, depositories and AMCs. Requirements varied by entity, low-value claims were subjected to the same documentation burden as large estates, and mandatory court-issued documents such as Probate of Will created delays even in straightforward cases.
As part of its ongoing "Ease of Doing Investment" agenda, SEBI reviewed the process followed by processing entities — listed companies, RTAs, depositories, DPs and AMCs — for effecting transmission. Acting under Regulation 40(7) of the LODR Regulations, as amended on July 10, 2026, SEBI has now prescribed a harmonised, standardised and risk-based transmission framework, annexed to this circular along with five sets of model forms.
The revised framework introduces a new low-value claims category, raises monetary thresholds for simplified documentation, removes several onerous requirements, and imposes firm processing timelines — while carving out contested claims for resolution through the courts rather than through the processing entity.
SEBI has directed processing entities to strive to process transmission requests received before August 22, 2026 under the new, simplified framework as well, so investors get the benefit of the revised procedure sooner rather than later. Where documents have already been submitted, entities cannot demand re-submission in the new formats.
Applicability and Scope
The framework applies to transmission of listed securities and units issued by AMCs upon the demise of the sole holder or all joint holders. It binds all listed companies, RTAs, depositories, DPs and AMCs uniformly.
The framework does not apply where there is any dispute or contesting/competing claim. Such cases must be resolved through appropriate judicial or legal proceedings, outside this simplified process.
Key Definitions
Any of: (i) an original death certificate, or a copy attested by the nominee subject to verification with the original; (ii) a copy attested by a notary, Gazetted Officer, or Judicial Magistrate First Class; or (iii) a death certificate bearing a QR code.
For a legal heirship certificate, means a revenue authority not below the rank of a Tehsildar or equivalent.
A certificate authenticating a public document (e.g., death certificate) for use in another Hague Apostille Convention country.
Quick Transmission Processing (QTP) and Revised Thresholds
The circular creates a new category — QTP — for very low-value claims, alongside a revised threshold for the existing simplified documentation route. Values are determined by the claimant using the previous closing price on any recognised stock exchange.
QTP is permitted only in favour of immediate relatives of the deceased — parents, spouse, children and parents-in-law.
Where a QTP claimant cannot furnish any standard proof of relationship (birth certificate, marriage certificate, Aadhaar, etc.), a notarised affidavit in the format prescribed at Annexure-B is accepted instead.
Note: the physical-mode threshold is applied per listed entity/Mutual Fund/SIF units in SOA form per AMC, while the demat-mode threshold is applied per beneficial owner — not as a single blanket cap across all of a claimant's holdings.
Documentation Requirements
Where a Nomination Exists
Nominee(s) receive the assets as trustee(s) on behalf of the legal heirs and must submit: the Transmission Request Form (Annexure-3), latest Client Master List (CML), a verifiable death certificate, and the original security certificate/statement of account. If a nominee predeceases the holder and the nomination is not updated, that nominee's share passes pro rata to surviving nominees. The entity is fully discharged of liability once assets are transmitted to the nominee(s).
Where There Is No Nomination
Transmission is made to claimant(s)/legal heir(s), subject to the following common and additional documents:
Transmission request form; latest CML; verifiable death certificate; original security certificate/copy of SOA.
A copy of the minor's birth certificate, school-leaving certificate, passport or Aadhaar (attested by the natural or legal guardian) must be furnished, along with KYC of the guardian. This applies regardless of which documentation category the claim falls under.
Wherever a claimant furnishes a court-issued document (Succession Certificate, Probate of Will, Letter of Administration or Court Decree), the notarised indemnity bond and/or affidavit-cum-NOC from non-claimant legal heirs is no longer required. Indemnity and affidavit-cum-NOC documents must be executed on non-judicial stamp paper as per the Stamp Act of the claimant's state. For claims above the simplified threshold, processing entities may seek additional documents only for recorded reasons.
Standard Procedure for Submission and Processing
- Use only the standardised forms at Annexures 2–5, made available physically and on the entity's website.
- Acknowledge receipt of the claim immediately, flagging any pending, missing, incomplete or incorrect documents at that time.
- Once all documents are received, issue a confirmation of complete submission to the claimant.
- Offer online submission with tracking where possible, though original documents may still need in-person verification.
- For physical securities, initiate demat conversion post-verification, intimate the claimant on completion, and — for locked-in securities — notify the depository of the lock-in period; the RTA retains and defaces the physical certificate.
- Communicate any procedural deviation to the claimant in writing, with reasons.
- Apply discretionary requests for additional documents consistently across similar cases and clients.
- Follow the same approach for securities transferred to the Investor Education and Protection Fund.
Proof of Death Occurring Outside India
A certified true copy of the foreign proof-of-death document is acceptable if certified via: a Court Magistrate, Judge or Notary Public in the country of issuance; consularisation by the Indian Embassy/Consulate General; apostille; or certification by authorised officials of overseas branches of Scheduled Commercial Banks registered in India, or of foreign banks with a correspondent banking relationship with Indian banks. If the certificate is not in English, a self-certified English translation must accompany the certified copy.
Timelines and Consequences of Delay
Entities must process a transmission claim within 21 calendar days of receiving all required documents (or such other period SEBI may specify). Delay or rejection must be communicated in writing with reasons. Where delay is attributable to the entity, SEBI may take appropriate action under applicable regulations. For physical-mode transmissions, the claimant must hold the original security certificate(s), except in duplicate-cum-transmission cases.
Rule of Survivorship
For transmission to a surviving joint holder on the demise of one or more joint holders, entities must continue to comply with clause 23 of Table F, Schedule 1, read with Sections 56(2) and 56(4)(c) of the Companies Act, 2013 (subject to the company's Articles of Association). In such survivorship cases, the entity may not seek any KYC, indemnity or undertaking from the surviving holder — only a copy of the death certificate of the deceased holder.
Monthly Reporting to SEBI
For a period of 6 months, processing entities must submit monthly reports to SEBI at [email protected], covering — for each category (QTP, Simplified, Above Threshold) — cases pending at month-start, cases received, approved, rejected, cases where additional documents were sought (with reasons), and cases pending at month-end.
Old vs New: Key Parameters Compared
Compliance Checklist for Processing Entities
☑ Update transmission SOPs and websites to reflect the QTP category and revised thresholds before the effective date (≈ August 22, 2026)
☑ Host standardised Annexure-2 to Annexure-5 forms on the website and make them available in physical mode
☑ Train front-line and back-office staff to distinguish QTP, Simplified and Above Threshold cases and apply the correct documentation grid
☑ Build an acknowledgement workflow that flags missing/incomplete documents at the point of receipt
☑ Set up internal tracking to meet the 21-calendar-day processing timeline and document reasons for any delay/rejection
☑ Establish a process to accept QR-code death certificates and the expanded foreign proof-of-death certification modes
☑ Prepare the monthly QTP/Simplified/Above Threshold reporting format for submission to [email protected] for 6 months
☑ Ensure survivorship cases are not asked for KYC/indemnity/undertaking beyond the death certificate
☑ Update claim-intake checklists to capture guardian KYC and minor's identity proof wherever a nominee, claimant or legal heir is a minor — required across QTP, Simplified and Above Threshold cases alike
☑ Avoid re-seeking documents already submitted for claims filed before the effective date
CorpLawUpdates Analysis
The most consequential change here is the creation of QTP as a distinct risk tier. By separating very low-value, close-family claims from the general transmission pool, SEBI is implicitly acknowledging that documentation intensity should scale with claim value and claimant proximity — a principle that has been missing from transmission practice for years. Removing the mandatory Probate of Will requirement is equally significant, since probate proceedings in Indian courts can take months or years, and this single change should meaningfully cut resolution time for a large share of claims.
The bigger risk isn't the new rules themselves — it's inconsistent application of the same rules across a fragmented network of RTAs, DPs and AMCs, each still running on legacy SOPs.
The practical compliance challenge will lie in consistent implementation across a fragmented ecosystem of listed companies, RTAs, depositories, DPs and AMCs, each with different legacy SOPs. SEBI's insistence on standardised forms (Annexures 2–5) and its explicit instruction that additional-document requests be "consistent across processing entities" suggests SEBI anticipates — and wants to pre-empt — divergent interpretations at the entity level.
The 6-month mandatory monthly reporting requirement is also worth flagging to compliance teams: it signals that SEBI intends to actively monitor real-world implementation (approval/rejection rates, additional-document requests, pendency) before deciding on any further calibration of thresholds or documentation.
Practitioners should watch for follow-on FAQs or clarificatory circulars from SEBI as processing entities begin operating the new grid, particularly around edge cases such as multiple nominees, minors as claimants, and claims involving both physical and demat holdings within the same folio.
This article is for informational and educational purposes only and does not constitute legal or regulatory advice. Verify with primary regulatory sources before acting.
