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How to Check Credit Rating Revisions of a Listed Company

By Flock Research · Filings research desk

Credit rating revisions of a listed Indian company leave two independent trails, and checking both is the whole method. The company must tell the stock exchanges, because a rating change is a deemed material event. The rating agency must publish its own press release on its website, on its own clock. When the two disagree on timing, the gap is itself information.

Definition

A credit rating revision

is a change by a credit rating agency to a rating previously assigned to an issuer or instrument. For a listed Indian company it is a deemed material event under item 3 of Para A of Part A of Schedule III to the SEBI LODR Regulations, disclosable to the stock exchanges without applying a materiality test. Source: SEBI.

Trail one: the company's announcement to the exchange

Schedule III to the LODR Regulations splits material events into two paragraphs. Para A events are deemed material and must always be disclosed. Para B events are disclosed only if the company's own materiality policy catches them. Rating changes sit in Para A, at item 3, which reads "New Rating(s) or Revision in Rating(s)".

That means a rating change is never a judgement call for the company. It goes to the exchange, under the Regulation 30(6) clocks that govern every material event: 30 minutes from the close of the board meeting where a decision was taken, 12 hours where the event emanates from within the company, and 24 hours where it does not. A rating action originates at the agency, not the company, so the 24 hour clock is the one that usually applies.

15 July 2023

The date from which a first-time rating became a deemed material event. The words 'New Rating(s) or' were inserted into Schedule III item 3 by the SEBI (LODR) (Second Amendment) Regulations, 2023; before it, only revisions were caught

Source: SEBI LODR Regulations, 2015, Schedule III, Part A, Para A, item 3

That date matters when you work backwards through an archive. An initial rating assigned in 2022 may simply not be in the announcement feed, because it was not then a deemed material event. Its absence is not evidence that no rating existed.

Trail two: the rating agency's press release

Rating agencies operate under their own rulebook. A credit rating agency is mandated to issue a press release after assigning a rating, in a standardised template, and to publish on its website a press release regarding a rating action, including reiteration of an existing rating, immediately and not later than 7 working days of the triggering event.

The standardised release carries more than the new symbol:

  • Rating transition and history, on any release reviewing a rating, so one document gives you the path rather than the point.
  • A Liquidity section, required as a specific named section.
  • Rating Sensitivities, explaining what would move the rating up or down.
  • Outlook, disclosed in the release.

For a reader, the sensitivities section is the most useful part, because it converts a symbol into the conditions attached to it.

The monthly signal underneath both trails

Every issuer must give its rating agency a No Default Statement at the end of each month, delivered on the first working day of the next month, explicitly confirming that no interest or principal payment was delayed in the previous month.

Two things follow from that mechanism.

If the issuer reports a delay in the statement, the agency must promptly conduct a rating review and disseminate the rating action through a press release within 2 working days of receiving the statement. That is the fastest clock in the system.

If the issuer stops submitting the statement, agencies follow a uniform practice of treating three consecutive months of non-submission as a ground for migrating the rating to Issuer Not Cooperating, tagging it within 5 working days of that third month, and the agency may migrate earlier in its judgement.

An INC tag is therefore not a rating opinion that the company got worse. It is a statement that the agency stopped being able to verify timely debt servicing. Those are different facts and they are routinely reported as if they were the same.

A practical order of checks

StepWhere to lookWhat it gives
1Exchange announcement filings for the companyThe dated disclosure, under Schedule III Para A item 3
2The rating agency's website press releaseTransition history, liquidity, sensitivities, outlook
3The company's websiteRegulation 46 requires all credit ratings obtained for listed non-convertible securities, updated immediately on any revision
4Gap between steps 1 and 2Whether the company disclosed on its own clock or after the agency published

Step 3 is the one most people skip. The website list is required to be kept current on revision, which makes it a cheap cross-check against a feed you may have read incompletely.

What a rating revision is not

It is not a view on the equity. A credit rating is an opinion on timely debt servicing, and an ESG rating answers a different question again. What a downgrade means for your own view of a company is your call to make.

Rating changes arrive in the same announcement feed as every other Regulation 30 disclosure. Flock reports the filings themselves, dated and linked to source. Not investment advice.

Frequently asked questions

Where does a listed company disclose a credit rating revision?

To the stock exchanges as a material event. Item 3 of Para A of Part A of Schedule III to the SEBI LODR Regulations reads "New Rating(s) or Revision in Rating(s)", which makes it deemed material and disclosable without applying any materiality test. Source: SEBI LODR Regulations, 2015, Schedule III.

Are first-time ratings disclosed too, or only revisions?

Both, since 15 July 2023. The words "New Rating(s) or" were inserted into Schedule III item 3 by the SEBI (LODR) (Second Amendment) Regulations, 2023 with effect from that date. Before it, only a revision was a deemed material event. Source: SEBI.

How quickly must a rating agency publish a rating action?

A credit rating agency must publish a press release on its website regarding the rating action, if warranted, immediately and not later than 7 working days from the occurrence of the triggering event. Source: SEBI Master Circular for Credit Rating Agencies dated 11 July 2025, paragraph 9.2.2.

What does an INC tag on a rating mean?

Issuer Not Cooperating. Rating agencies follow a uniform practice of treating three consecutive months of non-submission of the monthly No Default Statement as a ground for migrating a rating to INC, and must tag it within 5 working days of that third month. Source: SEBI Master Circular for Credit Rating Agencies dated 11 July 2025, paragraph 11.3.

Flock tracks these filings, sourced, dated, and linked back to the original. See what smart-money entities disclosed, without the guesswork about what it means.

Disclosures shown are public regulatory filings. Data may be delayed or incomplete. Smart-money entities may no longer hold positions shown. Not investment advice.

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