A high-level committee (HLC) chaired by former chief vigilance commissioner (CVC) Pratyush Sinha has submitted its report on 'conflict of interest, disclosures and related matters' concerning members and officials of the Securities and Exchange Board of India (SEBI). The report was formally presented to SEBI chairperson Tuhin Kanta Pandey on Monday at SEBI Bhavan in Mumbai, the market regulator says in an official release.
The SEBI board had, at its meeting held on 24 March 2025, decided to constitute the HLC to undertake a comprehensive review of existing provisions relating to conflicts of interest, property and investment disclosures, liabilities and related matters applicable to its members and employees. The committee’s recommendations are expected to strengthen SEBI’s governance framework and enhance institutional integrity within the regulator.
The six-member committee was chaired by Mr Sinha, a retired officer from the Indian Administrative Services (IAS) and included several eminent members from regulatory, corporate and academic backgrounds. The vice-chairman of the committee was Injeti Srinivas, IAS (retd), former secretary of the ministry of corporate affairs and former chairman of the International Financial Services Centres Authority (IFSCA). Other members included Uday Kotak, founder and director of Kotak Mahindra Bank, G Mahalingam, former executive director of the Reserve Bank of India (RBI) and former whole-time member of SEBI, Sarit Jafa, IA&AS (retd) and former deputy comptroller and auditor general and Prof R Narayanaswamy, former professor at the Indian Institute of Management (IIM), Bangalore.
According to SEBI’s release, the HLC was mandated to review the existing policies and frameworks governing conflict of interest and disclosure requirements, identify any gaps or ambiguities and recommend a robust, transparent and enforceable framework for preventing and managing potential conflicts. The committee’s terms of reference also included suggesting mechanisms for recusal, restrictions on personal investments, public disclosures, maintenance of digital records and systems for ongoing monitoring of compliance.
In addition to internal policy strengthening, the committee was tasked with recommending a mechanism for members of the public to raise concerns about conflicts of interest or improper disclosures involving SEBI officials. It was also expected to propose a process for examining such complaints to ensure greater public accountability and confidence in the regulator’s functioning.
SEBI’s statement noted that the formation of this HLC reflects the regulator’s commitment to uphold the highest standards of transparency, accountability and ethical conduct among its officials. “The committee’s review and recommendations aim to enhance the existing framework for managing conflicts of interest, disclosures, and related matters to ensure robust governance and ethical decision-making within SEBI,” the release stated.
The market regulator has been under increasing scrutiny in recent years, with growing emphasis on the need for regulators to maintain uncompromising ethical standards. The existing framework governing conflict-of-interest disclosures at SEBI, last updated in 2008, was seen as requiring a comprehensive review in light of evolving regulatory challenges and the increasing complexity of the financial markets.
According to earlier reports, SEBI had directed the committee to submit its recommendations within three months from the date of its constitution, after which the proposals would be placed before the SEBI Board for consideration and possible implementation. The report submitted by the Sinha-led panel marks the completion of that process, setting the stage for SEBI to deliberate on the proposed measures and, potentially, introduce revised disclosure and recusal norms for its members and officials.
While the contents of the report have not yet been made public, it is expected to cover recommendations for a digital disclosure system to track officials’ financial interests, mechanisms to prevent potential conflicts during policy formulation or enforcement actions and protocols for handling complaints from within and outside the organisation.
The report, submitted on 10 November 2025, will now be examined by SEBI’s top management and, subsequently, placed before the SEBI Board for discussion and approval.
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