India's regime lives in the SEBI (Prohibition of Insider Trading) Regulations, 2015, and the useful way to hold it is as a definition, two prohibitions and three obligations that generate published data.
How is unpublished price sensitive information defined?
The definition first. Unpublished price sensitive information, in Regulation 2(1)(n), has two limbs and both must hold. The information must relate to a company or its securities, directly or indirectly, and must not be generally available. And it must be information which, on becoming generally available, is likely to materially affect the price. Regulation 2(1)(e) defines generally available as accessible to the public on a non-discriminatory basis, which is a stricter test than "somebody could have worked it out". A figure sitting in a paid database that anybody can subscribe to is generally available; the same figure sitting in the chief financial officer's head is not.
Both limbs, in that order, kill most of the hard cases. Information already published in trade data fails the first limb however useful it is. A genuinely secret fact that would move the price by nothing fails the second. The deemed list in the regulation covers financial results, dividends, changes in capital structure, mergers and similar transactions, and changes in key managerial personnel. That list has been amended more than once, most recently in a 2025 expansion. Verify the current list and the exact wording of Regulation 2(1)(n) at sebi.gov.in, checked 7 September 2026.
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What do the two prohibitions say?
The two prohibitions are short. Regulation 3 forbids communicating unpublished price sensitive information except for legitimate purposes, and requires the board to have a policy defining what a legitimate purpose is. Regulation 4 forbids trading while in possession of it, with a presumption against connected persons that shifts the burden onto the person who traded.
A connected person under Regulation 2(1)(d) is anyone associated with the company in the six months before the act in any capacity that gives access. The definition expressly reaches association by reason of frequent communication with the company's officers, so a buy-side analyst who speaks to a chief financial officer four times a quarter is inside it. That surprises analysts and should not.
Three obligations then produce a feed you can read.
What is the trading window?
The first is the trading window. Clause 4 of Schedule B, read with Regulation 9, requires the company's code of conduct to close the window for designated persons whenever they can reasonably be expected to hold such information. For financial results the 2019 amendment made the closure mandatory and fixed its length: the restriction runs from the end of every quarter until 48 hours after the results are declared. A quarter ending 30 September 2026 with results published at 16:40 on 9 November has a window shut from 1 October until 16:40 on 11 November, which is 42 days. SEBI has since automated enforcement by freezing designated persons' permanent account numbers at security level, extended from April 2025 to their immediate relatives. Verify the current phase-in and the exact 48-hour wording at sebi.gov.in, checked 7 September 2026.
The window binds the company's designated persons. It does not bind an outside analyst, which is the most common confusion in the area. What binds the analyst is Regulation 4 and the code of conduct his own firm must maintain under Regulation 9 for intermediaries and fiduciaries.
How do trading plans and the insider database work?
The second is the trading plan. Regulation 5 lets an insider who is permanently in possession of price sensitive information trade at all, by pre-committing to a plan that is publicly disclosed and then executed mechanically. The June 2024 amendment cut the cooling-off period between disclosure of the plan and its first trade from six months to 120 calendar days. It also replaced the fixed twelve-month minimum duration with a stated execution period, and allowed the plan to name price limits within a 20 percent band around the previous close. Verify at sebi.gov.in, checked 7 September 2026; the pre-2024 six-month figure is still widely quoted.
The third is the structured digital database. Regulation 3(5) requires a record of the nature of every piece of unpublished price sensitive information shared, of who shared it, and of everyone it was shared with, each identified by permanent account number or another identifier. It must carry internal controls, time stamping and audit trails, and it may not be outsourced. Verify Regulation 3(5) at sebi.gov.in, checked 7 September 2026. As engineering it is an append-only log of who knew what and when, and its purpose is to make Regulation 4's burden-shifting operable. If the database says you were on the list, you were.
How does continual disclosure work?
Beside those sits the continual disclosure. Regulation 7(2)(a) requires every promoter, promoter group member, designated person and director to tell the company about securities acquired or disposed of, within two trading days, once the value traded in any calendar quarter exceeds ten lakh rupees. Regulation 7(2)(b) then requires the company to notify the exchange within two trading days of receiving it. The aggregation is what analysts miss. Four sales of ₹5,00,000, ₹3,40,600, ₹1,27,800 and ₹58,200 in one quarter total ₹10,26,600, and the fourth trade, worth ₹58,200, triggers disclosure of all of them. Verify the ten lakh threshold at sebi.gov.in, checked 7 September 2026; the regulation contemplates the figure being changed by specification.
Read as a data feed rather than as a rulebook, that last obligation is the interesting one. Every listed company in India publishes a stream of insider transactions, dated, sized and attributed by role, and the window tells you which weeks of the year that stream is structurally silent. A purchase disclosed in the second week after results carries different information from one disclosed in the week before quarter end, because only one of them was made by somebody who could have been holding the results.