19 Oct 2026 · weekly

Two new SEBI consultations, two investor tests

Two SEBI consultations entered the LobbyWatch ledger during 12–19 October: a paper dated 13 October on monitoring and disclosure of issue proceeds, and a paper dated 14 October on SME IPO rules.12

The first paper proposes direct reporting by monitoring agencies to stock exchanges, fines when listed companies do not cooperate, and mandatory monitoring agencies for all issuances, excluding offer-for-sale size. SEBI invites comments through 3 November.3 These proposals could make the use of raised funds more visible to investors; they are proposals, not rules in force.

The SME paper proposes a minimum application value of ₹1 lakh: four lots per application, with a minimum value of ₹25,000 per lot. It also proposes changes to eligibility, allotment and market-making rules. Comments are due 4 November.4 A higher application floor may make small-ticket participation harder; that is an access risk to test against the paper’s investor-protection rationale, not a claim about the final outcome.

Both papers invite feedback, but neither states that submissions or SEBI’s response will be published. The new consultation rows therefore leave comment-publication status unknown until a public record appears.56 That is the transparency test alongside the policy substance: whether investors can see what different interests asked for and how SEBI answered.

The doors ledger has no appointment dated 12–19 October. The RTI log still contains two template-ready entries and no filed request. Those are absences from LobbyWatch’s records, not proof that no meetings or requests occurred. Next watch: the two November comment deadlines, and whether the comment record becomes public.


  1. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-of-the-working-group-for-review-of-sebi-lodr-regulations-2015-review-of-framework-for-monitoring-and-disclosure-of-utilization-of-issue-proceeds_105242.html↩︎

  2. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-pursuant-to-review-of-provisions-of-sebi-issue-of-capital-and-disclosure-requirements-regulations-2018-related-to-initial-public-offer-by-small-and-medium-ente-_105252.html↩︎

  3. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-of-the-working-group-for-review-of-sebi-lodr-regulations-2015-review-of-framework-for-monitoring-and-disclosure-of-utilization-of-issue-proceeds_105242.html↩︎

  4. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-pursuant-to-review-of-provisions-of-sebi-issue-of-capital-and-disclosure-requirements-regulations-2018-related-to-initial-public-offer-by-small-and-medium-ente-_105252.html↩︎

  5. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-of-the-working-group-for-review-of-sebi-lodr-regulations-2015-review-of-framework-for-monitoring-and-disclosure-of-utilization-of-issue-proceeds_105242.html↩︎

  6. https://www.sebi.gov.in/reports-and-statistics/reports/oct-2026/consultation-paper-on-recommendations-pursuant-to-review-of-provisions-of-sebi-issue-of-capital-and-disclosure-requirements-regulations-2018-related-to-initial-public-offer-by-small-and-medium-ente-_105252.html↩︎

← All posts · Archive

The Sousveillance Stack — who writes, borrows and buys the rules