Form B vs Form C under SEBI PIT rules
On Form B vs Form C, the split is between a starting position and a change to it. Form B is filed once, when someone becomes an insider, and records what they already hold. Form C is filed again and again, each time their trading crosses the quarterly threshold. Both sit under Regulation 7 of the SEBI (Prohibition of Insider Trading) Regulations, 2015, and both were reissued in their current shape by the same SEBI circular. This guide compares them. It is not investment advice.
Definition
Form B versus Form C
are the two live disclosure formats under Regulation 7 of the SEBI PIT Regulations. Form B is the initial disclosure of holdings on becoming a KMP, director, promoter or promoter group member, due within seven days. Form C is the continual disclosure of trading. Source: SEBI PIT Regulations 2015.
Form B vs Form C compared
| What to check | Form B | Form C |
|---|---|---|
| Regulation | 7(1)(b) read with 6(2) | 7(2) read with 6(2) |
| Filed | Once, on becoming an insider | Every time the threshold is crossed |
| Trigger | Appointment as KMP or director, or becoming a promoter or promoter group member | Traded value over ten lakh rupees in a calendar quarter, in one transaction or a series |
| Deadline to the company | Seven days of the event | Two trading days of the transaction |
| What it records | Securities held at that moment, and open interest in derivatives | The holding before and after, the transaction type, mode and dates |
| Covers relatives | Yes, under Regulation 6(2) | Yes, under Regulation 6(2) |
7 days vs 2 trading days
Deadline to disclose to the company: Form B on becoming an insider, Form C after a qualifying transaction
Source: SEBI PIT Regulations 2015, Regulations 7(1)(b) and 7(2)(a)
What Form B actually asks for
Form B captures a snapshot rather than a movement. Its first table lists the person's name, PAN, CIN or DIN and address, their category, the date of appointment or of becoming a promoter or promoter group member, the type and number of securities held at that time, and the percentage of shareholding.
A second table records open interest in derivatives on the company's securities at the same moment, separately for futures and options, by contract specifications, number of units and notional value. This is why Form B is the baseline a later Form C is read against: without it, a first disclosed trade has nothing to sit on top of.
What happened to Form A
Regulation 7(1)(a), the one-time initial disclosure of holdings as on the date the regulations took effect, was omitted with effect from 26 April 2021 by the SEBI (Prohibition of Insider Trading) (Amendment) Regulations, 2021. The clause was transitional, so it did its work once when the 2015 regulations came in. Lists that still show Form A as a current filing format are describing an obligation that no longer has a parent provision.
And Form D
Regulation 7(3) is permissive rather than mandatory. A listed company may, at its discretion, require any other connected person or class of connected persons to disclose holdings and trading, in whatever form and frequency the company determines, in order to monitor compliance. SEBI publishes Form D as an indicative format for that, with the same column structure as Form C plus a connection-with-company field. Because it is discretionary, Form D disclosures are not comparable across companies the way Form B and Form C are.
The current versions of all three were annexed to SEBI circular SEBI/HO/ISD/ISD/CIR/P/2021/19 dated 9 February 2021, which revised Forms B to D after the regulations replaced "employee" with "designated person" and brought in members of the promoter group.
For the continual disclosure in detail, see Form C under SEBI insider trading rules and how to read a Form C disclosure. For the wider regime, see what is insider trading disclosure and what is a trading window closure.
Flock reads these disclosures as the exchanges publish them and keeps each one dated and linked to its source. What the data means for your money is your call to make.
Frequently asked questions
What is the difference between Form B and Form C?
Form B is the initial disclosure under Regulation 7(1)(b), filed once on appointment as a KMP or director or on becoming a promoter or promoter group member. Form C is the continual disclosure under Regulation 7(2), filed whenever quarterly trading crosses ten lakh rupees. Source: SEBI PIT Regulations 2015.
When is Form B due?
Within seven days. Regulation 7(1)(b) requires the person to disclose their holding of the company's securities as on the date of appointment, or of becoming a promoter or promoter group member, to the company within seven days of that event. Source: SEBI PIT Regulations 2015, Regulation 7(1)(b).
Is there still a Form A?
Its parent clause is gone. Regulation 7(1)(a), the one-time disclosure of holdings as on the date the regulations took effect, was omitted by the PIT Amendment Regulations, 2021 with effect from 26 April 2021. Form B and Form C are the live disclosure formats. Source: SEBI PIT Regulations 2015 as amended.
What is Form D for?
Other connected persons. Regulation 7(3) lets a listed company, at its discretion, require any other connected person to disclose holdings and trading, in the form and at the frequency the company decides. Form D is published as an indicative format for that. Source: SEBI PIT Regulations 2015.
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.