The Securities and Exchange Board of India (SEBI) issued a circular implementing amendments to the SEBI (Issue of Capital and Disclosure Requirements) Regulations, 2018 that allow specified securities for which a lock-in cannot be created to be recorded by depositories as “non-transferable” for the relevant lock-in period. To support the mechanism, depositories have issued an issuer-facing framework requiring, among other steps, suitable provisions in the issuer’s Articles of Association, intimation to relevant lenders or pledgees, and appropriate disclosures in offer documents. Depositories have also updated their systems and processes, and SEBI directed stock exchanges, depositories, merchant bankers and issuers to ensure compliance with the mechanism for lock-in of pledged shares.