ICSI requests SEBI for an extension of timelines due to COVID-19



Quick Summary
The Institute of Company Secretaries of India (ICSI) has formally requested an extension for certain compliance deadlines from the Securities and Exchange Board of India (SEBI). This request is prompted by the escalating COVID-19 pandemic and the subsequent restrictions imposed across major cities and states, which are hindering smooth operations for stakeholders. Specifically, ICSI is seeking dispensations for the requirement of proxy forms until December 31, 2021, for entities holding general meetings electronically, and an extension for holding Annual General Meetings for the top 100 listed entities until September 30, 2021.

The Institute of Company Secretaries of India has written a representation letter to SEBI, requesting an extension in the due dates of certain compliances amid rising cases of COVID-19 and restrictions imposed thereon in all major cities and states. Read the official representation letter below:

ICSI:PFP:2021 April 22, 2021 

Shri Amarjeet Singh 
Executive Director 
Securities and Exchange Board of India 
SEBI Bhavan, Plot No.C4-A, 'G' Block Bandra
Kurla Complex, Bandra (East) Mumbai - 400051 

ICSI Seeks SEBI Extension on Compliance Deadlines

Subject : Request for extension of timelines due to COVID-19-reg. 

Respected Sir, 

As your goodself is aware that the second wave of COVID-19 pandemic is spreading fast and economy is again gripping in the crisis. The situation in the major cities is again worsening and Government has imposed various restrictions to curb the impact. In these challenging times, stakeholders are finding it difficult to meet the ends and function smoothly. Considering the current crisis, we request your esteemed office to consider relaxations in due dates of the following compliances: 

S.No. Particulars Timeline Suggestion
SEBI (LODR) Regulations, 2015 
 1 Regulation 44 (4) - Requirement of proxy forms   The listed entity shall send proxy forms to holders of securities in all cases mentioning that a holder may vote either for or against a resolution   The requirement may be dispensed with upto December 31, 2021, in case of listed entities holding general meetings through electronic mode only 
 2 Regulation 44(5)- Holding of Annual General Meetings for top 100 listed entities  The top 100 listed entities by market capitalization, determined as on March 31st of every financial year, shall hold their AGM within a period of five months from the date of closing of the financial year i.e by 31st August, 2021  The extension in holding the AGM may be granted upto 30th September, 2021. 

To read more in details, find the enclosed attachment

FAQ :

The Institute of Company Secretaries of India (ICSI) has requested an extension from SEBI.

ICSI is requesting an extension due to the rising cases of COVID-19 and the restrictions imposed in major cities and states, which are making it difficult for stakeholders to meet compliance deadlines.

The request mentions the requirement of proxy forms (Regulation 44(4)) and the holding of Annual General Meetings for the top 100 listed entities (Regulation 44(5)).

ICSI suggests that the requirement for proxy forms may be dispensed with up to December 31, 2021, for listed entities holding general meetings solely through electronic mode.

An extension for holding Annual General Meetings for the top 100 listed entities is requested until September 30, 2021.




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