Designated Persons under SEBI Insider Trading regulations – Who are they?


Designated Person(s) under the SEBI Prevention of Insider Trading Regulations is what is referred to as an inclusive definition (meaning it includes those who are specified at a minimum but can include more as well).

Illustratively, under the regulations, it includes;

  • Various persons and roles such as promoters; directors;
  • Key managerial personnel;
  • Auditors;
  • All employees and support staff of various departments such as Accounts, Finance, Legal, Internal audit, Information technology and Secretarial Department.
  • Key Managerial Personnel of the material subsidiary of the Company;
  • Secretaries/EAs reporting to the Directors and the Key Managerial Personnel;
  • All Departmental Heads of the Company;
  • All employees up to two levels below the Board of Directors of the Company;

In addition, other persons may be identified by the Compliance Officer as well based on qualitative criteria outlined in the regulations.

Affinis(IDD) assists in identifying the list of persons who may potentially qualify as Designated Persons in a structured and logical manner that can be evidenced and also provide a formal record of the list.

The list of Designated Persons is also used to manage Designated Person compliances.

Affinis(IDD) maintains an evidentiary trail of notices of compliance obligations and provides reports as required.