What SEBI expects from an insider trading audit trail

The question behind every inspection

When SEBI examines an insider trading control framework, the underlying question is always the same: can this organisation prove, after the fact, who had access to unpublished price-sensitive information, when they had it, and what they did while they had it? Policies assert the answer. An audit trail demonstrates it.

That distinction shapes what an examiner actually asks for: not your code of conduct, but your UPSI register with timestamps, your pre-clearance history with approvals and rejections, and your trading window records with the alerts that enforced them.

UPSI records: the register is the control

A UPSI register maintained in a spreadsheet has a fatal property — it can be edited without trace. Regulation 3(5) expects a structured digital database with the nature of the information, the persons who received it, and immutable timestamps. If the record can be silently amended, it proves nothing.

The practical standard is an append-only store: entries are written once, corrections are new entries that reference the old, and the full history is reconstructible for any date the examiner names.

Pre-clearance: decisions with evidence attached

For every trade by a designated person, the examiner wants the request, the checks that ran, who approved it, and when. Multi-level authorisation only counts if each level is separately recorded — a single 'approved' flag collapses the chain of accountability the regulation is trying to create.

Window state at the moment of approval matters as much as the approval itself. A system that checks the trading window automatically, and records that it checked, removes the most common gap examiners find.

What good looks like

The organisations that clear inspections quickly share one property: their answers are queries, not investigations. The register, the approvals and the window history live in one system, and any state the examiner asks about can be reproduced in minutes.

That is the bar we built the Insider Trading Compliance Platform against — 100% regulatory adherence in production, with 70% less manual effort than the manual controls it replaced.

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