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First identify which Regulation 74(5) document or step is missing: an RTA or participant certificate connected to a dematerialisation request, the issuer’s filing of a quarterly certificate with an exchange, or the public posting of a filing already made. The next action depends on that distinction. Issuers should check their exchange and disclosure records and contact their registrar and transfer agent (RTA) in writing; investors with a pending demat request should start with the depository participant (DP) handling it.
Identify what is missing before following up
“Regulation 74(5) certificate” is used in related but distinct contexts under India’s SEBI (Depositories and Participants) Regulations, 2018. Do not assume the same party holds every document or that every use of the label has the same deadline or filing route. SEBI’s circular discusses issuer/RTA processing of demat requests, while issuer disclosures and secretarial compliance reports also describe quarterly certificates and exchange filings.
| What appears to be missing | What to check first |
|---|---|
| A certificate or confirmation in a dematerialisation request | Identify the security and request date, then ask the DP that accepted the request and the issuer/RTA which processing step remains outstanding. |
| The issuer’s exchange filing for a quarter | Check the company’s exchange filing portal and its investor-relations disclosure page for the relevant quarter, then ask the RTA whether it issued or sent the certificate. |
| A public copy of a filing | Compare the exchange record with the issuer’s disclosure page. The filing may exist even if it is not readily visible on the public page. |
An issuer disclosure page, for example, groups these certificates under quarterly dematerialisation certificates and publishes quarter-ended examples: issuer disclosure example.
If you are the issuer or company secretary
Check the relevant records
Search the exchange filing portal and the company’s investor-relations disclosures for the quarter in question. Record whether the certificate itself is absent, whether a filing was submitted but is not visible, or whether the RTA has not yet supplied the document. Confirm the applicable exchange and filing route for the issuer rather than relying on another company’s disclosure page.
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Ask the RTA for a dated status
Contact the RTA in writing. Specify the quarter or demat request and ask for the certificate, its issue date, dispatch details, and the reason for any delay. A 2025 secretarial compliance report describes a company filing after receiving the certificate from its RTA on November 5, 2024; another report attributes a delay to non-receipt from the RTA. These are examples of an RTA being a relevant contact, not a universal procedure.
File when available and preserve the trail
Once the document is available, complete any filing required for the company and retain the request, RTA response, certificate, submission acknowledgement, and relevant exchange correspondence. The reports document delayed filings and later filing after receipt, but they do not establish a safe harbor from enforcement.
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If you are an investor with a pending demat request
Contact the DP that accepted the request and the issuer/RTA. Give the security details and request date, and ask which processing step remains outstanding and whether the required certificate or confirmation has been issued. SEBI’s circular connects Regulation 74(5) with issuer/RTA demat processing, but the cited material does not establish a complete current investor escalation timetable. Check current official guidance for the complaint route applicable to your case.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to interpret deadlines and possible consequences
Keep the two 15-day references separate. SEBI’s April 16, 2020 circular identifies an existing 15-day timeline for issuer/RTA processing demat requests. It also describes COVID-era measures affecting calculation of time and backlog; those temporary measures should not be treated as current relief. Read SEBI’s 2020 circular.
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A 2025 secretarial compliance report separately describes a listed entity’s obligation to file the certificate with each exchange within 15 days of quarter end, records a five-day delay, and says the delay was due to non-receipt from its RTA. That is a company-specific report and description, not by itself proof of the current deadline for every issuer or filing.
Before stating a due date, extension, or consequence, have the company secretary or securities-law adviser check the current SEBI text, the relevant exchange’s latest instructions, and the issuer’s listing status. The cited reports show that delays can be recorded as non-compliance, but they do not establish a fixed automatic fine for every delay. If an exchange has issued a notice or specific direction, review that communication and respond through the applicable process.
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Keep a concise evidence record
- Note the document type, quarter or demat request, and the date the issue was identified.
- Save written follow-ups to the RTA or DP, together with replies and stated reasons for delay.
- Keep the certificate, filing acknowledgement, and any exchange notice or correspondence.
- Record which current rule or exchange instruction was used to confirm the deadline and filing route.
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