SEBI Proposes Raising ISIN Limit For Privately Placed Debt Securities From 14 To 17

On 10 August, the Securities and Exchange Board of India (SEBI) proposed increasing the maximum number of International Securities Identification Numbers (ISINs) maturing in a financial year for privately placed debt securities from 14 to 17 to facilitate fund raising and improve issuers' asset liability management.

Under the existing framework, issuers can have a maximum of 14 ISINs maturing in a financial year, comprising nine ISINs for plain vanilla debt securities and five for structured and market linked debt securities.

SEBI said market participants had sought a review of the existing limits, stating that the restriction could lead to “bunching of liabilities”, creating difficulties in liquidity management and increasing refinancing risk, particularly for Non-Banking Finance Companies.

Under the proposal, up to 12 ISINs would be permitted for plain vanilla debt securities, while five ISINs would continue to be available for structured debt securities, market linked debt securities, Floating Rate Bonds, Zero Coupon Bonds and Debt Capital Instruments. Where the outstanding amount across the 12 plain vanilla ISINs maturing in a financial year reaches Rs. 15,000 crore, one additional ISIN would be permitted for every additional issuance of Rs. 3,000 crore.

SEBI has also proposed excluding Government of India serviced or Extra Budgetary Resources bonds and ESG debt securities while calculating the applicable ISIN limits. It has further proposed dispensing with the requirement for an issuer to list all outstanding unlisted non-convertible debt securities issued on or after 1 January 2024 when it seeks to list a non-convertible debt security.

Public comments on the proposals have been invited until 31 August 2026.