What is a monitoring agency report? (2026)

A monitoring agency report is a quarterly report by a SEBI-registered credit rating agency on how a listed company actually spent the money it raised from an issue, measured against the objects it published in the offer document. It exists because the gap between "we will build a plant" in a prospectus and where the cash went two years later used to be invisible. The report is filed with the stock exchanges and put on the company's website, so any investor can read it. It is not investment advice.

When is a monitoring agency report required?

The trigger is size, and the size that matters depends on the route. For a mainboard public issue, Regulation 41 of the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 requires a monitoring agency where the issue size exceeds 100 crore rupees, excluding the offer for sale portion by selling shareholders. That exclusion matters: money paid to an exiting shareholder never reaches the company, so there is nothing to monitor.

Do not carry that number across to the other routes, because it has moved. The SEBI (ICDR) (Amendment) Regulations, 2025 cut the SME IPO threshold under Regulation 262(1) from 100 crore rupees to 50 crore rupees, also excluding the offer for sale, with effect from March 8, 2025; and a rights issue under Regulation 82 now requires a monitoring agency irrespective of issue size, with effect from April 8, 2025. If you are checking whether a particular company should have one, check its route first.

One exclusion cuts across all three routes. The proviso to each of Regulations 41(1), 82(1) and 262(1) says the requirement does not apply to an issue of specified securities by a bank, a public financial institution or an insurance company. Those issuers are prudentially supervised elsewhere, so a rights issue by a bank will not have a monitoring agency report however large it is, and its absence is not a compliance gap.

Two earlier changes widened the regime. An ICDR amendment effective January 14, 2022 moved the monitoring role to a credit rating agency registered with SEBI, replacing the earlier public financial institution or scheduled commercial bank. A further amendment effective November 21, 2022 extended monitoring to preferential issues and QIPs above a 100 crore rupee threshold, which until then were monitored only where stressed assets were involved. Coverage now runs across most routes a listed company uses to raise equity, including SME IPOs.

What does the report actually contain?

The format is prescribed at Schedule XI of the ICDR Regulations, which is why every one of these reports looks alike. Read across a few filings and the useful columns are the same:

The last row is the one people skip. The regulation requires the board of directors and the management to comment on the monitoring agency's findings, and those comments sit inside the same document. When an agency flags a deviation and the board's answer is thin, that is on the public record next to the number.

How is a monitoring agency report published?

The agency reports to the issuer every quarter, and the issuer must publicly disseminate that report by uploading it on its website and submitting it to the stock exchanges within 45 days from the end of each quarter. Reporting continues until the issue proceeds are fully utilised, not for a fixed number of quarters. A company that raised money in 2024 for a project still running in 2026 is still filing.

The route into the report on the exchange side is Regulation 32(6) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, which requires a listed entity with a monitoring agency to submit the agency's comments or report to the exchanges. Regulation 32(7) then requires those reports to be placed before the audit committee on a quarterly basis, promptly upon receipt. That frequency was substituted for "an annual basis" with effect from January 24, 2022, so older write-ups describing it as annual are out of date. On the exchange filing systems these land tagged to Regulation 32, alongside the statement of deviation the company files itself.

Why does this filing matter to an outside investor?

It is one of the few disclosures that closes the loop on a prospectus. The red herring prospectus states what the money is for, in detail, because SEBI requires it. Everything after listing is normally reported as revenue and profit, which tells you nothing about whether the specific promised capex happened. The monitoring agency report is the follow-up, quarter by quarter, in the same categories as the original promise, signed off by a third party rather than only by the company.

Two limits are worth being honest about. First, the agency verifies utilisation against stated objects; it does not opine on whether the spending was a good idea. Second, money parked under "general corporate purposes" is inherently less traceable than money earmarked for a named plant, which is exactly why SEBI caps that head in the offer document.

So, what is a monitoring agency report: a quarterly, third-party, public record of how issue proceeds were actually spent against what was promised, required above a route-specific size and filed until the money runs out. Reading it alongside the objects of the issue is a straightforward way to check a company's follow-through, and it pairs with the other material event disclosures a listed company files. Flock reads these public filings and stamps each one with its date and source. What any of it means for you is your call to make.