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N-PX vs SEBI voting disclosure: US and India

By Flock Research · Filings research desk

N-PX vs SEBI voting disclosure is the same question asked in two markets: how did the fund holding this company vote its shares? The United States answers it once a year in a single filing on EDGAR. India answers it four times a year, on each asset management company's own website, with a written reason attached to every vote. Each design gives up something the other keeps. This guide sets them side by side. It is not investment advice.

Definition

N-PX vs SEBI voting disclosure

is the difference between a centralised annual filing and a distributed quarterly posting. Form N-PX goes to the SEC on EDGAR by 31 August for the year to 30 June. Indian AMCs publish votes cast on their own websites within 10 working days of each quarter end, with a rationale per resolution. Source: SEC and SEBI.

N-PX vs SEBI voting disclosure at a glance

Form N-PX (United States)SEBI voting disclosure (India)
Who filesRegistered funds, and since 2024 institutional managers that file Form 13FAsset management companies, covering all their schemes
Filed withThe SEC, on EDGARNobody; published on the AMC's own website
FrequencyAnnualQuarterly, plus the annual report
Period coveredTwelve months to 30 JuneEach calendar quarter
Deadline31 AugustWithin 10 working days of quarter end
ScopeFunds: all matters. 13F managers: executive-compensation matters onlyAll resolutions voted
Rationale requiredNoYes, per resolution
Duty to voteNot imposed by the form itselfCompulsory since 1 April 2022 on all resolutions
Single searchable sourceYes, EDGARNo

What each design gets right

The US record is findable. Every Form N-PX is filed under Rule 30b1-4 on EDGAR, free to read, in one system. You can go from a fund to its votes without knowing anything about that fund's website. Anyone who has tried to assemble the same picture across a dozen Indian fund houses will recognise what that is worth. For the mechanics of searching, see how to search EDGAR.

The Indian record is timelier, wider, and explains itself. Three differences carry real weight:

  • Frequency. Quarterly against annual. A US vote cast in July 2026 falls into the year ending 30 June 2027 and publishes by 31 August 2027, which can be more than a year later.
  • Scope for large managers. The 2024 expansion of N-PX brought in Form 13F managers, but only for executive-compensation items: say-on-pay, say-on-frequency, and golden-parachute proposals. How a large US manager voted on a director election or an auditor is not in its N-PX. An Indian AMC discloses every resolution.
  • The rationale. SEBI requires the specific reason for each vote. N-PX records the vote, not the reasoning. On a contested resolution the reason is often the whole story.

Quarterly vs annual

Indian AMCs publish votes cast within 10 working days of each quarter end; US filers report on Form N-PX once a year for the twelve months to 30 June, due 31 August

Source: SEBI and SEC

Reading both

Neither record tells you what a fund owns. That comes from Form 13F in the United States and the quarterly shareholding pattern in India. The voting disclosures tell you what the holder did with the influence attached to those positions, which is the part that shows up in a company's governance rather than in its price.

For the Indian framework behind the quarterly file, including the six principles and the phased duty to vote, see what is the SEBI Stewardship Code. For the practical routine of collecting the files, see how to track mutual fund voting disclosures. Flock reads disclosure filings and keeps each one dated and linked to its source. What any of it means for your money is your call to make.

Frequently asked questions

What is the difference between Form N-PX and SEBI voting disclosure?

Form N-PX is an annual report filed with the SEC on EDGAR covering the twelve months to 30 June, due by 31 August. SEBI voting disclosure is a quarterly posting on each Indian asset management company's own website, due within 10 working days of quarter end. Source: SEC and SEBI.

Which voting record is easier to search?

Form N-PX, because every filing lands in one place, the SEC's EDGAR system, in a structured form. SEBI voting disclosures are published by each AMC on its own website in its own format, so there is no single database and comparing houses means normalising the files yourself. Source: SEC and SEBI.

Does Form N-PX cover every resolution?

It depends on the filer. Registered funds report votes on all matters they voted. Institutional managers that file Form 13F report only executive-compensation matters: say-on-pay, say-on-frequency, and golden-parachute proposals. Indian AMCs disclose every resolution they voted. Source: SEC and SEBI.

Do Indian funds have to explain their votes?

Yes. SEBI requires the AMC to record and disclose the specific rationale supporting each decision to vote for, against or abstain. That written reason has no direct equivalent in the Form N-PX structure, which records the vote rather than the reasoning behind it. Source: SEBI and SEC.

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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