Prohibition of Insider Trading, UPSI & Structured Digital Database

Velox Compliance, is a workflow software to simplify automation of SEBI regulations on Prohibition of Insider Trading.

What if you had?

Complete visibility over Request & Reporting

Automated trade request approvals/rejections based on preset rules

Control over UPSI & SDD to be compliant

Automatic reminders for periodic submissions

Easy access to employee profile, request, reporting and defaulter list

Stay on top by automating your compliance processes to manage SEBI regulations
with an eye to mitigate insider trading risks.

Quick Facts

30+ installations with over 15,000+ users

8 Large Mutual Funds

2 Life Insurance Companies

10 Broking Houses

3 Merchant Banks

2 Advisory Firms


  • For Employee
  • For Compliance Team
  • Workflow
  • Grey List & Restricted Scrip
  • UPSI Management
  • Alerts & Notifications

Self Declarations

Initial holding uploads

Dependent declarations

Automated and assisted submissions

Submission calendar

Monitor and approve transactions

Control defaulter transactions

Define blackout periods

Define category-based approval workflow

Define submission policies

Enable automatic and manual approvals

Automated grey list integration

Manual setup of restricted & intention list

UPSI disclosure & Structured Digital Database (SDD)

Auto restrict UPSI security

UPSI Annexure submission

Define system driven alerts

Approval notifications

Policy updates via email


For Compliance

Policy Setup

Annexure Setup

Check Request Inbox

Access Employee Details


Ensure Compliance

For Employee

Self Declaration

Declare Dependants

Initial Holdings



Submit Periodic Annexures

Frequently Asked Questions (FAQ) on Insider Trading

What is Insider Trading?

Insider trading is defined as a malpractice wherein trade of a company's securities is undertaken by people, who by virtue of their work or relationship with the people working with the company (defined as Insider), have access to the otherwise non-public information which can be crucial for making investment decisions.

It gives an unfair advantage to the Insider with respect to understanding the financial position of the company, whereas the other shareholders and investors are at a great disadvantage due to lack of important insider non-public information.

What are SEBI Regulations on Prohibition of Insider Trading?

SEBI has made the compliance officer of an organisation to be responsible for monitoring all the trade made by Access/ Designated employees and close the trading window for the trade if the employees could be in possession of non-public Information.

It mandates the compliance department to create a base framework (using sebi guidelines on Prohibition of insider trading ) for regulating the Trading in securities by Employees as well as their Dependants including spouses.

What is Structured Digital Database for UPSI?

As per the new amendment, SEBI has made additional compliances where all listed companies and connected persons as defined under the regulation are required to maintain a structured digital database with adequate internal controls, containing the name(s) and PAN Number(s) of the person(s) with whom UPSI is shared and the nature of UPSI. Also maintaining a list of all employees and other persons with whom unpublished price sensitive information is shared and confidentiality agreements signed.

What are the latest amendments of SEBI Insider Trading Regulations?

On July 17, 2020, SEBI notified the Securities and Exchange Board of India (Prohibition of Insider Trading) (Amendment) Regulations, 2020 (“PIT Amendment”), to introduce further changes to the PIT Regulations.

  • Enhancement of the structured digital database towards seeking and storing additional details of persons sharing unpublished price sensitive information (“UPSI”)
  • Automation of shareholding disclosures and change in reporting authority for making disclosures of PIT violations by listed entities, market intermediaries and fiduciaries.
  • Introduction for additional transactional mechanisms as an exception to trading window restrictions.
What are the periodic disclosures requirements as an insider?

Initial disclosure

Every Promoter, Key Managerial Personnel and Director of the Company whose securities are listed on any recognized stock exchange shall disclose (Form 4) his holding of securities of the Company as on the date of these regulations taking effect to the Company within thirty days of these regulations taking effect

Continual Disclosure

Every promoter, designated employee and Director of every Company shall disclose in Form 5 & 6 to the Company the number of such securities acquired or disposed of within two trading days of such transactions if the value of the securities traded, whether in one transaction or a series of transactions over any calendar quarter, aggregates to a traded value in excess of Rs.10 lakhs or such other value as may be specified.

How many times has SEBI amended the insider trading policy?

The base guidelines for Prohibition of Insider Trading is as per SEBI insider trading guidelines 1992. SEBI has been making amendments to the policy every year to ensure Insider trading policy framework becomes more robust. Few of the major recent amendments have been coming almost every year i.e. 2015, 2018, 2019 as well as in 2020.

Do I need an automation solution to manage the regulation?

Tracking details like Initial Holding, Transaction Requests, Transaction Reporting, Periodic Disclosures, for employees as well as all the dependents, is a huge task while managing it using a combination of emails and excel sheets.

It also becomes almost impossible to track violations of Holding period/ Contra transactions, UPSI as well as Restricted lists for different employees using excel information.

How much does it cost to automate using Velox?

- Our pricing is based on the number of named users.

- Currently available as an on-premise license i.e. the software is installed at your premise or on your own private cloud, with 2 payment options.

  • a) You can choose to pay a one-time license fee with recurring annual maintenance charges.
  • b) You can choose to pay on a monthly prorated basis which is billed annually when you sign-up.
  • c) A one-time configuration fee is applicable for both options a & b.

Discover how Velox can help you be compliant with SEBI regulations on Prohibition of Insider Trading