CORAA

Insider Trading Compliance Audit Checklist (SEBI PIT Regulations)

UPSI handling, trading window closures, the structured digital database, and the designated persons list — the controls SEBI's PIT Regulations, 2015 actually require, tested end to end.

Free · CORAA original — SA-aligned
Updated 28 Jul 2026
Governing regulation
SEBI (Prohibition of Insider Trading) Regulations, 2015
Key record
Structured Digital Database (SDD) — Regulation 3(5)
Common gap
DP list based on title/designation, not actual UPSI access
Format
Microsoft Word (.docx)
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Your firm — letterhead
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Engagement details
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What’s inside

An excerpt from the template.

INSIDER TRADING COMPLIANCE AUDIT CHECKLIST

Entity: ___ · Period: ___

Scope: compliance with SEBI (Prohibition of Insider Trading) Regulations, 2015 — applicable to listed companies and, for certain provisions, intermediaries and fiduciaries. Covers Unpublished Price Sensitive Information (UPSI) handling, trading window closures, the Structured Digital Database (SDD) under Regulation 3(5), and the Designated Persons (DP) list under the Code of Conduct.

Risk & Control Matrix

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About this template

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This template follows the format published by the Institute of Chartered Accountants of India (ICAI) in the AASB Audit Working Paper Templates (June 2023), the authoritative reference for Indian statutory-audit documentation. Fill in your firm’s letterhead and the engagement details on the form above, click Download Word file, and you’ll get a fully formatted .docx ready to use.

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Common questions

FAQs.

Does this checklist apply to unlisted companies?
The SEBI PIT Regulations, 2015 primarily govern listed companies and their designated persons. However, certain provisions — particularly the Structured Digital Database requirement — also extend to intermediaries and fiduciaries (such as auditors, law firms, and merchant bankers) who come into possession of UPSI in the course of their engagement, even where the company itself is not the intermediary's own listing.
Why is the Structured Digital Database specifically called out as a common gap?
Regulation 3(5) requires a time-stamped, tamper-proof internal record of every person with whom UPSI is shared and the nature of the UPSI, maintained for a minimum retention period. A frequent finding is that this database either does not exist, exists only informally (e.g. an email trail, not a proper database), or has gaps corresponding to periods of high deal activity — precisely when it matters most.
Who should be on the Designated Persons list?
The DP list should be based on actual access to UPSI, not job title alone — a mid-level finance team member preparing draft results has UPSI access and should be a DP, even if a senior manager in an unrelated function does not. A list built purely off an organisation chart of "senior management" designations is a common audit finding, since it both over- and under-includes the wrong people.
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