The Securities and Exchange Board of India has updated its master circular on surveillance of the securities market, consolidating instructions for stock exchanges, depositories, listed companies, intermediaries and fiduciaries into a single reference point. The revised circular incorporates three later measures covering financial disincentives for surveillance-related lapses at market infrastructure institutions, permission for subscription to non-convertible securities during trading window closure, and automated trading window restrictions for immediate relatives of designated persons, while rescinding earlier circulars to the extent they deal with the same subject matter. The consolidated circular brings together the main surveillance and insider trading compliance requirements. These include rules for trade-for-trade treatment in specified cases, controls on unauthenticated market news circulated by registered intermediaries, disclosure and reporting obligations under the Prohibition of Insider Trading Regulations, and system-driven continual disclosures. It also embeds the framework for financial disincentives at market infrastructure institutions, where surveillance-related lapses are defined around failure to implement surveillance decisions, discharge surveillance activities or report on time. The disincentives are linked to the institution's annual revenue and the number of lapses in a financial year, ranging from INR 1 lakh to INR 1 crore per instance, with any amount imposed to be credited to the SEBI Investor Protection and Education Fund within 15 working days. On trading window restrictions, the circular confirms that subscriptions to issues of non-convertible securities, along with offer for sale and rights entitlements transactions, are outside trading window restrictions when undertaken under the Board's framework. It also consolidates the PAN-ISIN freeze framework for designated persons and their immediate relatives during financial-results-related trading window closures, covering on-market transactions, off-market transfers and pledge creation in the relevant equity shares and equity derivatives. Depositories must submit quarterly reports to SEBI on implementation of that framework, while compliance officers, designated persons and their immediate relatives must continue to meet their obligations under the insider trading rules until further communication.