# The Holdings and Personal Details People Must Report

> Mandatory disclosure timelines for shareholding changes and material financial relationships\.

## 7. The holdings and personal details people must report

New directors and key managerial personnel, and people becoming promoters or promoter-group members, must disclose their company-security holdings within **seven days** of appointment or acquiring that status.

Promoters, promoter-group members, designated persons and directors must report acquisitions or disposals when traded value, individually or cumulatively, exceeds **₹10 lakh in a calendar quarter**, unless another limit is specified. Reporting is due within **two trading days of the transaction**. After a disclosure, further transactions trigger reporting when they again cross the threshold.

The company must notify exchanges within two trading days of receiving the disclosure or otherwise becoming aware. Disclosures include legally permitted derivatives—contracts whose value depends on underlying securities—and their traded value. They also cover trades by immediate relatives and people whose trading decisions the reporting person makes. The decision-maker’s possession of UPSI matters even if someone else owns the investment.

Companies retain these disclosures for at least **five years**. Listed companies may require other connected persons to disclose holdings and trades at company-set intervals. Internal codes also require trade and holding reports; company and Schedule C codes must record decisions not to use a trading approval.

Designated persons separately disclose prescribed information about immediate relatives and people with whom they have a **material financial relationship**, annually and whenever details change. This includes names, PAN or another permitted identifier, and phone numbers used. Graduation institutions and previous employers are disclosed once. These relationship requirements also appear in mutual-fund and Schedule C codes.

A material financial relationship means someone received payments, including loans or gifts, from the designated person during the preceding 12 months totalling at least **25% of that designated person’s annual income**. Arm’s-length payments—transactions on independent commercial terms—are excluded.

Keep the different clocks separate. A trading day is a day when recognised stock exchanges are open. Other provisions use calendar days, working days or business days; they should not casually be treated as interchangeable.