How to track use of IPO proceeds (2026)

To track use of IPO proceeds you compare one document against two recurring filings: the objects of the issue in the offer document, then the quarterly statement of deviation and, above a size threshold, the monitoring agency report. All three are public. The comparison is mechanical, and it is the most direct way to check whether the plant, the debt repayment or the acquisition a company raised money for actually happened. This guide walks the steps. It is not investment advice.

How to track use of IPO proceeds, step 1: read the objects of the issue

Start at the promise. For a mainboard IPO, the objects of the issue sit in the red herring prospectus, broken into named heads with a rupee amount and, usually, a deployment schedule by financial year. For a preferential issue or a QIP, the equivalent is the explanatory statement to the notice calling the general meeting.

Three things to note down, because everything later is measured against them:

1. the amount against each named object, and how much sits under general corporate purposes, which is inherently harder to trace than a named asset;
2. the deployment schedule, so you know which quarter a spend was meant to land in;
3. the fresh issue amount only. Money paid to selling shareholders in an offer for sale never reaches the company, so it is outside all of this.

Step 2: pull the quarterly statement of deviation

Every listed entity with unspent issue proceeds files a statement of deviation or variation with the stock exchanges each quarter under Regulation 32 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. It reports outright deviations from the stated objects and the category wise variation between projected and actual utilisation, and the audit committee must review it before it is filed.

Practical notes for finding and reading it:

• It travels with the quarterly results cycle. Regulation 33 sets those at 45 days from quarter-end and 60 days from the financial year-end, so that is the window to look in.
• For a company on an SME exchange, Regulation 32(8) reads the requirement as half yearly. Two filings a year is compliance, not a missing filing.
• Read the sequence, not one filing. The detail of the document is covered in what is a statement of deviation.

Step 3: pull the monitoring agency report

Where the route's threshold is met, a SEBI-registered credit rating agency must act as monitoring agency. For a mainboard public issue that is issue size exceeding 100 crore rupees, excluding the offer for sale, under Regulation 41 of the SEBI ICDR Regulations, 2018. The SEBI (ICDR) (Amendment) Regulations, 2025 set the SME IPO threshold at 50 crore rupees on the same ex-offer-for-sale basis from March 8, 2025, and made a monitoring agency mandatory for a rights issue irrespective of issue size from April 8, 2025. Two things to check before concluding a report should exist: the route, and the issuer type, because each of Regulations 41(1), 82(1) and 262(1) exempts an issue by a bank, public financial institution or insurance company. The agency reports every quarter in the format at Schedule XI, and the issuer must publish that report on its website and file it with the exchanges within 45 days from the end of each quarter, until proceeds are fully utilised.

This is the higher-quality source of the two, for one reason: it is prepared by someone other than the company, and the regulation requires the board and management to comment on the agency's findings in the same document. Regulation 32(6) of the LODR Regulations is what routes it to the exchanges, and Regulation 32(7) puts it before the audit committee quarterly, promptly upon receipt. The full anatomy is in what is a monitoring agency report.

An SME issuer below the threshold is not left with nothing. Regulation 262(5), inserted by the same 2025 amendment, requires it to file a statutory auditor's certificate on utilisation of the money raised, excluding the offer for sale, with the SME exchange each time it files its quarterly financial results, until proceeds are fully used. Regulation 262(6) adds a further requirement where the object is working capital above a specified size. So on the SME board, below that threshold, the third-party check is an auditor's certificate rather than a rating agency's report.

Step 4: close the year with the annual report

Two annual disclosures catch anything the quarterly filings smoothed over:

• Regulation 32(4): where funds were used differently from the offer document, the company must explain the variation in the directors' report.
• Regulation 32(5): an annual statement of funds used for purposes other than those stated must be certified by the statutory auditors and placed before the audit committee.

An auditor-certified statement is a materially stronger artefact than a management assertion, so if a deviation exists, this is where the cleanest version of it is recorded.

What does the trail actually tell you?

The honest limits: none of these documents judges whether the spending was wise, delays in a capex project are common and disclosed as such, and money under general corporate purposes will never trace as cleanly as a named asset. What the trail does give you is a dated, sourced record of promise against execution, which is more than most narratives about a company are built on. It reads best alongside the rest of a company's material event disclosures.

That is how to track use of IPO proceeds: objects of the issue, then the quarterly deviation statement, then the monitoring agency report, then the annual auditor-certified statement. Flock reads these public filings and keeps each one stamped with its date and source. What any of it means for you is your call to make.