HO/17/11/12(3)2025-DDHS-POD1/ I/144/ 2025 — THE SECURITIES AND EXCHANGE BOARD OF INDIA ACT, 1992

CIRCULAR HO/17/11/12(3)2025-DDHS-POD1/ I/144/ 2025 To, All Registered Debenture Trustees, Issuers who have listed and/ or propose to list debt securities, and Recognized Stock Exchanges Dear Sir/ Madam, Sub: Timeline for submission of information by the Issuer to the Debenture Trustee(s) In terms of the provisions of Regulations 15(1)(s) and 15(1)(t) of the SEBI (Debenture Trustees) Regulations 1993 ('DT Regulations'), DT shall carry out due diligence on a continuous basis. Chapter II of the Master Circular for Debenture Trustees dated August 13, 2025 ('DT Master Circular') 1 has specified the manner in which the DT shall carry out due diligence for creation of security at the time of issuance of debt securities. Further, Chapter VI of the DT Master Circular has, inter-alia, specified that the issuer and the Debenture Trustee shall ensure that the terms and conditions relating to periodical monitoring are incorporated in the debenture trust deed. In order to enable the DTs to perform their function efficiently and in a timely manner, the issuer shall submit the reports/ certificate to the Debenture Trustees as follows: 1 Master Circular no. SEBI/HO/DDHS -PoD -1/P/CIR/2025/117; November 25, 2025 The provisions of this circular shall come into effect from quarter ended December 31, 2025. This circular is issued in exercise of powers conferred under Section 11(1) of Securities and Exchange Board of India Act, 1992, Regulation 2A of the DT Regulations, Regulation 101 of the SEBI (Listing Obligations and Disclsoure Requirements) Regulations, 2015, and Regulation 55 of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021, to protect the interest of investors in securities and to promote the development of, and to regulate, the securities market. This c