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Introduction of the “Companies Fresh Start Scheme, 2020” and revised the “LLP Settlement Scheme, 2020” to provide relief to law abiding companies and Limited Liability Partnerships (LLPs) in the wake of COVID-19

In order to reduce compliance burden during the unprecedented public health situation caused by COVID-19, the Ministry of Corporate Affairs, on 30 March 2020 issued a press release pertaining to the introduction of the “Companies Fresh Start Scheme, 2020” and revised the “LLP Settlement Scheme, 2020” (the revised LLP Settlement Scheme, 2020 is available here), which is already in effect, to provide a first of its kind opportunity to both companies and LLPs to make good any filing related defaults, irrespective of the duration of default, and make a fresh start as a fully compliant entity.

During the period starting from 1st April 2020 and ending on 30th September 2020, the following benefits are available to companies and LLPs, under the Fresh Start Scheme and Modified LLP Settlement Scheme, respectively:

It incentivizes compliance and reduces compliance burden;
Companies and LLPs are permitted to file any and all belated filings i.e., filings that the company or LLP are yet to carry out and for which the statutorily prescribed time limit has expired;
A one-time waiver of additional filing fees for delayed filings by the companies or LLPs with the Registrar of Companies;
Provides longer timelines for entities to comply with various filing requirements under the Companies Act, 2013 and Limited Liability Partnership Act, 2008;
Significantly reduces certain financial burden on companies and LLPs, especially for those with long standing defaults, thereby giving them an opportunity to make a “fresh start”;
Provides the opportunity to file for immunity from penal proceedings, including against imposition of penalties for late submissions and provides additional time for filing appeals before the concerned Regional Directors against imposition of penalties, if already imposed. However, the immunity is only against delayed filings in MCA21 and not against any substantive violation of law. The application seeking immunity shall be filed after 30 September 2020, and can be filed only if there are no pending appeals against notices or adjudicated orders (appeals, if any, are to be withdrawn before filing application for immunity).

Suspension of Limitation Period

Taking suo moto cognisance of difficulties faced by litigants in view of the COVID-19 pandemic, and to avoid overcrowding at filing counters in courts, the Supreme Court has passed an order dated 23 March 2020 with respect to the period of limitation for filing requirements.

A 3 judge bench of the Supreme Court headed by the Chief Justice of India, exercising its powers under Article 142 read with Article 141 of the Constitution of India, directed that the period of limitation in all proceedings before any Court/Tribunal, irrespective of the limitation prescribed under the general law or special law, whether condonable or not, would stand extended with effect from 15 March 2020 till any further orders passed by the Supreme Court in this regard.

In effect, if the limitation period for filing of any proceeding, be it a petition, application, suit, appeal or any other proceeding, expired on or after 15 March 2020, the same stands extended. The date till which limitation would stand extended will be notified by the Supreme Court in its subsequent orders.

The order, having been passed under Articles 141 and 142 of the Constitution of India, has the effect of law and is binding on all courts, tribunals and authorities.

Notification issued by the MoHFW in order to regulate the doorstep delivery of drugs to consumers

Pharmacy in a supermarket during coronavirus pandemic. BRISTOL, UK, March 30, 2020

The Ministry of Health and Family Welfare, on 26th March 2020 notified that retail sale of drugs to the doorstep of consumers is essential to meet the requirements of emergency arising due to pandemic COVID-19. Therefore, in order to regulate the sale and distribution of drugs for their delivery to customers, the following directions have been issued:

In case any person holding a license in Form-20 or Form-21 under the Drugs and Cosmetics Rules, 1945 intends to sell, stock or exhibit or offer for sale, or distribute drugs by retail, intends to sell any drug including the drugs specified in Schedule H except narcotics, psychotropics and controlled substances as defined in the Narcotic Drugs and Psychotropic Substances Act, 1985 and the drugs as specified in Schedule H1 & Schedule X to the said rules, by retail with doorstep delivery of the drug, the licensee can sell such drugs subject to the condition that:

Any such sale of a drug specified in Schedule H shall be based on receipt of prescription physically or through e-mail; The licensee shall submit an e-mail ID for registration with the licensing authority if prescriptions are to be received through email; The drugs shall be supplied at the doorstep of the patients located within the same revenue district where the licensee is located; In case of chronic diseases, the prescription shall be dispensed only if it is presented to the licensee within 30 days of its issue and in acute cases, the prescription shall be dispensed only if it is presented to licensee within 7 days of its issue; and The bill or cash memo shall be sent by the return email and records of all such transactions shall be maintained by the licensee.

SEBI takes steps to make short selling harder – Press Release 20 March 2020

On 20 March 2020, SEBI issued a press release taking note of the continued volatility in Indian and global stock markets and observed that significant market movements had not yet disrupted settlement cycles in India. SEBI announced a slew of measures which came into effect at the start of trading on 23 March 2020 for a period of 1 month (subject to review at the end of this period).

These changes include revision of market wide position limits for stocks in the futures and options segment, increase in margin for stocks in the futures and options segment, increase in cash market margins for stocks which are not futures/options, revised position limits for equity index derivatives, and flexing of dynamic price bands for futures and options stocks.

Revision of Market Wide Position Limit (MWPL)[1]:

For futures and options stocks (“F&O Stocks”) whose:

(a) average Daily Price High Low variation percentage[2] (during last 5 trading days) was more than or equal to 15%; or,

(b) whose average MWPL utilization percentage (during last 5 trading days) was more than or equal to 40%,

MWPL may be revised to 50% of the existing levels. This re-calculated MWPL shall be used to impose ban periods on fresh positions and not to determined enhanced eligibility criteria for derivative stocks.

If MWPL utilization for any security crosses 95%, derivative contracts will enter a ban period and further trading will be allowed only to decrease positions through offsetting positions[3].

Stock exchanges and clearing corporations have been instructed to put monitoring mechanisms in place and to conduct checks on an intra-day basis. Violations will result in penalties that will range from an amount 10 times higher than the current minimum penalty up to an amount 5 times higher than the current maximum penalty.

Increase in margin rate in Cash Market:

For the stocks mentioned in (1) above, the margin to be maintained in the Cash Market will be increased in a phased manner: 20% (as on 23.03.2020); 30% (from 26.03.2020); and 40% (from 30.03.2020). These will apply for 1 month.

Revised position limits in equity index derivatives:

Mutual Funds, foreign portfolio investors, proprietary trading members and clients shall be subject to the following limits in equity index derivatives:

(a) Short position[4] shall not exceed the notional value of their holding of stocks; and

(b) Long position[5] shall not exceed their holding of treasure bills, cash, government securities and similar instruments.

Additionally, equity index futures contracts and equity index options contracts shall each be capped at INR 500 crores.

Breach of these conditions will require an additional deposit that is twice the margin amount (chargeable on the excess) and stock exchanges and clearing houses shall retain such deposits for 3 months. However, positions that existed prior to the circulars issued by stock exchanges and clearing houses were permitted to continue till their expiry.

This position applies to institutional and proprietary trading members for 1 month from 23 March 2020. For all others, it applies on and from 27 March 2020.

Flexing of dynamic price bands for F&O stocks:

As on date of this press release, F&O stocks are subject to a dynamic price band which relaxes based on certain specified market movement in either direction. For instance, if at least 25 trades occurred involving no less than 5 unique client codes (UCC) on each side of the trade, where each trade is at or above 9.9% of the base price.

To prevent premature relaxation of price bands, SEBI has now imposed a 15-minute cooling off period. After the relevant F&O stock satisfies any requirement specified by a stock exchange to qualify for a relaxation of the price band, no relaxation can occur until the expiry of a mandatory 15-minute cooling-off period.

These measures were taken by SEBI to prevent market distortion. For instance, after the implementation of this press release, speculative short selling has become much harder, given that the changed margin requirements make it expensive, there is now a limit of number of shares that can be traded in the derivatives segment, and there is a sharp increase in penalty for violation of these revised norms.

SEBI’s timely actions, both in easing the compliance burden on listed entities and in acting swiftly to stem the tide of market volatility are laudable and, one expects, will improve our market resilience.

[1] A market-wide position limit is defined, with respect to a specific underlying stock, as the maximum number of open positions allowed across all futures and options contracts of that stock.
[2] This is the percentage of the difference between the highest and lowest trading values of a particular stock on any given trading day.
[3] i.e. the taking of an equivalent but opposite position to reduce the net position to zero.
[4] In layman terms, this is the sale of a stock the investor does not own in the belief that she will buy it in future – this is based on the assumption that the price of the stock is expected to fall in future, therefore they expect to make a profit by selling the stock at a higher price now and buying it a lower price later.
[5] In layman terms, this is the purchase of a security in the hope that it will increase in value.

Tags SEBI

Guidelines issued to the management of factories and establishments

In the backdrop of the catastrophic outbreak of COVID-19, the Ministry of Labour and Employment of India on 20 March 2020[1], has advised the Employers of Public/ Private Establishments to extend their coordination by not terminating their employees, particularly, casual or contractual workers from job or reduce their wages. If any worker takes leave, he should be deemed to be on duty without any consequential deduction in wages for this period. Further, if the place of employment is to be made non-operational due to COVID-19, the employees of such unit will be deemed to be on duty.

The Government of Karnataka, on 22 March 2020[2] ordered that all shops, commercial establishments, workshops, godowns dealing with non-essential services be closed. And all labour intensive industries must work at 50% of their strength on rotation basis. The Government has also advised that the employers do not remove any worker on this account and to sanction paid leave on these days to the remaining workers.

The Government of Telengana, vide a notification[3] has ordered for closure of all shops and establishments, except as notified, between the period from 22 March 2020 to 31 March 2020 and declared it as a paid holiday for all categories of employees.

The government of Tamil Nadu, Haryana and Odisha have issued certain guidelines to the management of factories /establishments in view of the prevailing COVID-19 outbreak. These guidelines have been issued on in order to ensure strict compliance with the measures that every factory/ an establishment should necessarily undertake and follow so that it results in containing the spread of COVID-19, as one of the major tools to prevent the spread of COVID-19 is by way of observing social distancing, Therefore, one should adopt highest level of hygiene and sanitation along with social distancing. The following guidelines have been formulated on these lines:

Promote frequent handwashing;
Workers should be encouraged to stay home if they are sick;
Never avail public transport facility to hospital, if suspected of possible exposure of COVID-19;
Encourage respiratory etiquettes;
Establish policies and practices which facilitate flexible worksite and work hours;
Discourage workers from using others’ phones, desks, tools or equipment’s to the extent possible.
Avoid grouping;
Prompt identification and isolation of infected individuals;
Educate the employees to self-monitor signs and symptoms of COVID-19;
The district administration should be informed of any employees who has returned from a foreign location or if someone from any foreign location has visited the premises of the factory/establishment;
Provide personal protective equipments like prescribed nose mask, face shield / goggles, gloves, apron etc.;
Provide facilities for safe disposal of the soiled nose mask, gloves, apron etc.
Provide facilities for drying clothing
Resist from insisting on the medical certificate of employees who are sick with acute respiratory illness;
Permit employee to stay at home to take care of a family member who has been sick;
Reduce the number of employees on site, allowing them to maintain distance from one another;
Maintain regular housekeeping practices including routine cleaning and disinfecting of surfaces, equipment’s and other elements in the factory/establishment;
Maintain the canteens and dining rooms in proper hygienic condition;
If possible, all workers or visitors, to be screened by infrared thermometer before entering the premises;
Avoid bio-metric attendance of the people;
To the extent possible, every establishment/factory should have an isolation room, or atleast an area designated with closable doors;
Creches shall be specifically monitored and disinfected thoroughly;
Health provisions prescribed in chapter III of the Factories Act, 1948 and Chapter VII of The Building and Other Construction Workers Act, 1996 and related provisions of the Tamil Nadu Factories Rules, 1950 and Tamil Nadu BOCW Rules, 2006 should be strictly complied with;
Factories having public address/virtual display system may utilize the same for educating workers on the measures for preventing possible exposure of COVID-19.

The most effective way of containing the spread of COVID-19 is by way of observing ‘social distancing’. Government establishments including Secretariat, Directorates, District Level Offices and Sub-district Level Offices as well as certain private establishments including shops, workshops and factories that remain operational during the said period will have to comply with the following guidelines, in order to break the chain of contact to prevent the further spread of the disease. In this regard, the government of Odisha has formulated the following guidelines:

[1] https://labour.gov.in/sites/default/files/file%201.pdf
[2] No. DD/SSU/COVID-19/17/19-20
[3] G.O. Rt No. 160 available at https://goir.telangana.gov.in/

Tags SOCIAL DISTANCING

Special measures notified and implemented by the Ministry of Corporate Affairs

Following are the special measures notified and implemented by the Ministry of Corporate Affairs (MCA) under Companies Act, 2013 and Limited Liability Partnerships Act, 2008 in view of COVID 19 outbreak.

Exemption on additional filing fees	Any additional fees which is applicable for late filings to any Company or LLPs, will not be charged during a moratorium period from April 01, 2020 to September 30, 2020, in respect of any document, return, statement etc., required to be filed in the MCA registry, irrespective of its due date.
Holding Board meetings as per section 173 of the Companies Act, 2013	As a one-time relaxation the gap between two consecutive meetings of the Board has been extended to 180 days till September 30, 2020, instead of 120 days.
Applicability of The Companies (Auditor’s Report) Order, 2020	The Companies (Auditor’s Report) Order, 2020 will now be applicable from financial year 2020-21 instead of being applicable from 2019-20.
Para VII (1) of Schedule IV to Companies Act, 2013	For the financial year 2019-20 the Independent Directors are allowed to share their views via telephone or email or any other mode of communication (if they deem to be necessary). This is in lieu of their meeting which is required to be held during the financial year 2019-20.
Deposit repayment reserve- Section 73(2)(c) of Companies Act, 2013	Creation of deposit repayment reserve of 20% of deposits maturing during the financial year 2020-21 before April 30, 2020 will now be allowed to complied with till June 30, 2020.
Declaration for commencement of business- Section 10A of the Companies Act, 2013	An additional period of 180 days is allowed for filing this declaration.
Relaxation to Rule 18 of the Companies (Share Capital & Debentures) Rules, 2014	Time period for investing or depositing at least 15% of amount of debentures maturing in specified methods of investments or deposits before April 30, 2020 can now be complied with June 30, 2020.
Resident director compliance requirements-Section 149 of the Companies Act, 2013	For the financial year 2019-20 the requirement of meeting 182 days by a resident director has been relaxed.

This initiative of MCA is to support and enable Companies and LLPs in India to focus on taking necessary measures to address the COVID-19 threat, including the economic disruptions caused by it.

India under Lockdown – Center invokes Disaster Management Act to contain COVID-19. What happens to State orders?

The Indian Prime Minister, Mr. Narendra Modi, while addressing the nation on March 24, 2020, announced a nationwide lockdown for 21 days to contain the spread of COVID-19.

Shortly thereafter, the National Disaster Management Authority (“NDMA”) issued an order dated March 24, 2020 under the Disaster Management Act, 2005 (“DM Act”) noting that it was satisfied that the country is threatened by the spread of COVID-19, and that there is an urgent need to bring about consistency in the application and implementation of various measures across the country while ensuring maintenance of essential services and supplies (“NDMA Order”). To this end, the NDMA directed that necessary guidelines be issued immediately.

Pursuant to the NDMA Order, and in exercise of the powers conferred under Section 10(2)(l) of the DM Act, 2005, the Ministry of Home Affairs, through the National Executive Committee under the DM Act, issued an order dated March 24, 2020 (“Lockdown Order”) for the prevention and containment of COVID-19. The Lockdown Order will be operative for a period of 21 days, with effect from March 25, 2020.

Under the Lockdown Order, all States and Union Territories need to ensure strict implementation of the guidelines set out therein, which can be accessed here.

The Lockdown Order has effectively placed India under a nationwide lockdown for 21 days. In the days leading up to the Lockdown Order, several State Governments had issued orders notifying curfews and restrictions in their respective States for containment and prevention of COVID-19 (“State Orders”). At the time of writing, the State Orders have not yet been revoked by the respective States. However, under Section 72 of the DM Act, the provisions of the DM Act will have an overriding effect over any other law or instrument issued under any other law for the time being in force. Accordingly, the guidelines issued under the Lockdown Order will, to the extent of any conflict with the previous State Orders, have an overriding effect. Therefore, all State Governments would need to comply with the guidelines issued under the Lockdown Order.

That being said, State Governments are also empowered under Section 38 of the DM Act to undertake such further measures, over and above the guidelines issued by the NDMA, they may deem necessary or expedient. Therefore, there is no restriction on States to implement further or more stringent measure than those set out in the Lockdown Order, provided such measures are not in conflict the Lockdown Order. Accordingly, measures taken by State Governments under previous State Orders will continue to have force, to the extent that they are not in conflict with the Lockdown Order.

It remains to be seen whether any State Government will implement further or more stringent measures, given the variation in the impact of COVID-19 across States.

Tags LOCKDOWN

21-day nationwide lock-down – Guidelines issued by the Ministry of Home Affairs

On 24 March 2020, the Ministry of Home Affairs vide its order no. 40-3/2020-DM-I(A) issued guidelines to be followed by ministries/departments of the Government of India, State/ Union Territory Governments and Authorities, containing measures to combat the spread of COVID-19.

These guidelines were issued by the National Executive Committee under the directions of the National Disaster Management Authority (order No. 1-29/2020-PP(Pt. II) dated 24 March 2020) and in exercise of its powers conferred under Section 10(2)(l) of the Disaster Management Act, 2005.

The Guidelines, inter alia, provide for the following containment measures which shall remain applicable for a period of 21 days with effect from 25 March 2020:

All offices of the Government of India, its autonomous/subordinate offices and public corporations shall remain closed except for defence, central armed police forces, public utilities (including petroleum, LPG, CNG, PNG), disaster management, power generation and transmission units, post offices, National Informatics Centre, Early Warning Agencies etc. Certain offices, like that of the treasury, MCA-21 registry, GSTN, RBI etc., shall function with bare minimum staff.
The offices of the State/Union Territory Governments, their autonomous bodies and corporations etc. shall remain closed except for police, home guard, civil defence, fire and emergency services, disaster management, prisons, district administration and treasury, electricity, water, sanitation and municipal bodies (relating to essential services like water supply and sanitation only), Mandis operated by the Agricultural Produce Market Committee or as notified by the state government, etc.
All hospitals and related medical establishments including dispensaries, chemist, medical equipment shops, laboratories, clinics, nursing homes, ambulance, veterinary hospitals, pharmacies and pharmaceutical research labs etc. shall remain functional. Further, transportation of medical personnel, nurses, other hospital support services etc. shall be permitted.
All commercial and private establishments to be closed other than shops dealing in food, groceries, fruits and vegetables, dairy, meat, fertilizers, seeds, pesticides etc.; bank, ATMs, insurance offices; print and electronic media; telecommunication, internet services, broadcasting and cable services; delivery of essential goods through e-commerce; petrol pumps, LPG, petroleum and gas retail and storage outlets; power generation and transmission units; private security services; farming operations by farmers and farm workers in the field, etc.
All industrial establishments shall remain closed; other than those engaged in the manufacturing of essential goods, including drugs, pharmaceuticals, medical devices, their raw materials and intermediates; those production units which require continuous process and have obtained the approval from the state government; coal and mineral production, transportation, supply of explosives etc.; manufacturing units of packaging materials for food items, drugs, pharmaceuticals and medical devices and manufacturing and packaging units for fertilizers, pesticides and seeds.
All transport services, other than for the transport of essential commodities or of fire or law and order or emergency services or for cargo movement, relief and evacuation and their related operational organisations, inter-state movement of goods/cargo for inland and exports, transit arrangements for foreign nationals in India according to the specified standard operating procedure, etc., shall remain suspended.
All educational, training, research, coaching institutions etc. to remain closed.
All places of worship shall remain closed.

(Please refer to the Guidelines, the first Addendum to the Guidelines (dated 25 March 2020), the second Addendum to the Guidelines (dated 27 March 2020), the third Addendum to the Guidelines (dated 02 April 2020), the fourth Addendum to the Guidelines (dated 03 April 2020) and the fifth Addendum to the Guidelines (dated 10 April 2020) for the complete list of containment measures and exceptions)

Wherever any exception has been provided to the containment measures, the organisation/ employer shall ensure necessary precautions, including social distancing measures, as advised by the Health Department.

Any violation of the containment measures specified in the Guidelines shall be liable to action under Sections 51 to 60 of the Disaster Management Act, 2005 and Section 188 of the Indian Penal Code, 1860.

Tags GST, LOCKDOWN, SOCIAL DISTANCING

SEBI relaxes compliance requirement pertaining to Mutual Funds, REITs and InvITs

SEBI, vide its circular dated 23 March 2020 (SEBI/HO/IMD/DF3/CIR/P/2020/47) has provided for the following relaxations in compliance requirement with respect to mutual funds.

A. Relaxations specified in SEBI (Mutual Funds) Regulations, 1996 and circulars issued thereunder:

All schemes (NFO) which are yet to be launched but where observation letter was issued by SEBI shall remain valid for a period of 1 year from the date of such SEBI letter.
All new schemes (NFO) where final observation letter is yet to be issued shall remain valid for a period of 1 year from the date of the SEBI letter.
Timelines for disclosures have also been relaxed, as follows:

Particulars of disclosure/ Regulation/ Circular	Frequency	Original Due Date	Extended Date
Half yearly disclosures of unaudited financial results as required under Regulation 59 of SEBI (Mutual Funds) Regulations, 1996	Half yearly 1 month from the close of the half year, i.e, 31 March 2020.	30 April 2020	31 May 2020
Disclosure of commission paid to distributors as required under Point 2(a) of SEBI circular No. SEBI/HO/IMD/DF2/CIR/P/2016/42 dated 18 March 2016	Half yearly Within 10 days from the half year end i.e. 31 March 2020	10 April 2020	10 May 2020
Yearly disclosure of investor complaints with respect to Mutual Funds as required under Point 4 (b) of SEBI circular No. Cir/IMD/DF/2/2010 dated 13 May 2010	Yearly Within 2 months of the close of the financial year i.e. 31 March 2020	31 May 2020	30 June 2020

B. Extension in the date of implementation for certain policy initiatives:

Circular	Particulars	Original Due Date	Extended Date
Risk management framework for liquid and overnight funds and norms governing investment in short term deposits dated 20 September 2019	Liquid funds shall hold at least 20% of its net assets in liquid assets	1 April 2020	1 May 2020
Review of investment norms for mutual funds for investment in Debt and Money Market Instruments dated 1 October 2019	Existing open ended mutual fund schemes shall comply with the revised limits for sector exposure	1 April 2020	1 May 2020
Review of investment norms for mutual funds for investment in Debt and Money Market Instruments dated 1 October 2019	Maximum investment in unlisted NCDs as % of the debt portfolio of the scheme.	15% – 31 March 2020	15% – 30 April 2020
Valuation of money market and debt securities dated 24 September 2019	Amortization based valuation shall be dispensed with and irrespective of residual maturity, all money market and debt securities shall be valued in terms of paragraph 1.1.2.2 of the Circular.	1 April 2020	1 May 2020

Further, SEBI issued a circular on 23 March 2020 (SEBI/HO/DDHS/CIR/P/2020/42), extending the due date for regulatory filings and compliances for REITs and InvITs for the period ending 31 March 2020 by 1 month, over and above the timelines prescribed under the SEBI (Infrastructure Investment Trusts) Regulations, 2014 and SEBI (Real Estate Investment Trusts) Regulations, 2014 and related circulars.

Tags SEBI

SEBI grants extension for filings related to listing of NCDs and more

In continuation of the circular of 19 March 2020, SEBI issued a circular on 23 March 2020 (SEBI/HO/DDHS/ON/P/2020/41) further relaxing certain timelines with respect to listed entities.

Particular	Frequency	Date of available Audited Financials	Original Date of Issuance	Relaxation Period	Extended Date of Issuance
Cut-off date for issuance of NCD/ NCRPS/ CP	Within 6 months of the date of the latest audited financials	30 September 2019	On or before 31 March 2020	60 days	On or before 31 May 2020

2. Extension of timeline for filings under SEBI (LODR) Regulation 2015

Regulation and Filings	Frequency	Original Due Date	Relaxation Period	Extended Date
Large Corporate-Initial Disclosure and Annual Disclosure (SEBI Circular HO/DDHS/CIR/P/2018/144 dated November 26, 2018)	Yearly
Initial Disclosure – within 30 days from the beginning of Financial Year	30 April 2020	60 days	30 June 2020
Annual Disclosure – within 45 days from the end of Financial Year	15 May 2020	45 days	30 June 2020
Non-Convertible Debentures (NCDs) / Non-Convertible Redeemable Preference Shares (NCRPS)
Regulation 52 (1) and (2) relating to Financial Results	Half Yearly/ Yearly
45 days from the end of the Half Year	15 May 2020	45 days	30 June 2020
60 days from the end of Financial Year for Annual Financial Results	30 May 2020	30 days	30 June 2020
Common obligations prescribed under Chapter-III of SEBI (LODR) Regulations, 2015	As prescribed in SEBI Circular SEBI/HO/CFD/CMD1/CIR/P/2020/38
Commercial Papers (CPs)
Financial Results	Half yearly/Yearly
45 days from the end of the Half Year	15 May 2020	45 days	30 June 2020
60 days from the end of Financial Year for Annual Financial Results	30 May 2020	30 days	30 June 2020

3. Extension of timeline for filings prescribed for Issuers of Municipal Debt Securities

Regulation and Filings	Frequency	Original Due Date	Relaxation Period	Extended Date
Investor Grievance Report as per Municipal Bond	Half Yearly	Within 30 working days from end of the Half Year	45 days	30 June 2020
Financial Results	Half Yearly 60 days from the end of Financial Year for Annual Financial Results	30 May 2020	30 days	30 June 2020
Accounts maintained by Issuers under ILDM Regulations	Quarterly 45 days from end of quarter