Securities Exchange Board of India (SEBI) vide Notification No. SEBI/HO/CFD/CMD1/CIR/P/2020/109 dated 25th June, 2020 has come out with Further extension of time for submission of Annual Secretarial Compliance Report by listed entities due to the continuing impact of the CoVID-19 pandemic in exercise of the powers conferred under Section 11(1) of the Securities and Exchange Board of India Act, 1992 read with Regulation 101 of the SEBI (LODR) Regulations, 2015.

The Circular was issued to:

1. All listed entities
2. All Recognized Stock Exchanges

Previous Extension:

1. Circular No. SEBI/HO/CFD/CMD1/CIR/P/2020/38 dated March 19, 2020 (Regulation 33 of SEBI LODR)

Sl no.	Regulation and associated filing	Filing		Relaxation w.r.t. the quarter / financial year ending March 31, 2020
		Frequency	Due within	Due Date	Extended date	Period of relaxation
1	Regulation 24A read with circular No CIR/ CFD/CMD1/27/2019 dated February 8, 2019 relating to Secretarial Compliance Report	Yearly	60 days from the end of Financial Year	30.05.2020	30.06.2020	1 month

Reason behind further extension from 30th June 2020 to 31st July 2020.

Various representation has been received by SEBI from listed entities, Institute of Company Secretaries of India (ICSI), and industry bodies/associations seeking further extension of time for submission of the Annual Secretarial Compliance Report in view of the:

1. difficulties and challenges faced by listed entities and
2. Practicing Company Secretaries due to the continuing impact of the CoVID-19 pandemic.

Further Relaxation from SEBI
SEBI has decided to:

1. SEBI has further extended the timeline for submission of the ASC Report by one more month, t, to July 31, 2020, for the Financial Year ended 31st March 2020.

Applicability of this Circular: shall come into force with immediate effect.

Brief note on ASCR:

1. Applicable Laws: Regulation 24A of SEBI (LODR), Regulations, 2015 & SEBI Circular dated Feb. 8, 2019
    
2. As per Regulation 24A: Secretarial Audit
   Every listed entity and its material unlisted subsidiaries incorporated in India shall undertake secretarial audit and shall annex with its annual report, a secretarial audit report, given by a company secretary in practice, in such form as may be prescribed with effect from the year ended March 31, 2019.
    
3. Reporting Requirement under Annual Secretarial Compliance Report:
   It is a compliance check mechanism of all applicable SEBI Regulations and circulars/ guidelines issued thereunder, consequent to which, the PCS (Practicing Company Secretary) shall submit a report to the listed entity in the manner specified in SEBI circular dated 08.02.2019.
    
4. Applicability:
   applicable to listed entities, with effect from the financial year ended March 31, 2019 onwards.
    

Link of SEBI Circular on ASCR:

• https://www.sebi.gov.in/legal/circulars/feb-2019/format-for-annual-secretarial-audit-report-and-annual-secretarial-compliance-report-for-listed-entities-and-their-material-subsidiaries_42015.html
• https://www.sebi.gov.in/legal/circulars/mar-2020/relaxation-from-compliance-with-certain-provisions-of-the-sebi-listing-obligations-and-disclosure-requirements-regulations-2015-due-to-the-covid-19-virus-pandemic_46360.html
• https://www.sebi.gov.in/legal/circulars/jun-2020/further-extension-of-time-for-submission-of-annual-secretarial-compliance-report-by-listed-entities-due-to-the-continuing-impact-of-the-covid-19-pandemic_46933.html

Disclaimer:
In No Event The Author Shall Be Liable For Any Direct, Indirect, Special Or Incidental Damage Resulting From Or Arising Out Of Or In Connection With The Use Of This Information.