SDI Annexure I vs Annexure II: the two formats
SDI Annexure I vs Annexure II is the difference between two securitisation disclosure formats that share a deadline, a filer and a title, and almost nothing else. SEBI's circular of 16 December 2025 prescribes both under Regulation 11B of the SEBI (Issue and Listing of Securitised Debt Instruments and Security Receipts) Regulations, 2008. Which one a deal files depends entirely on what backs the pool. Anyone reading across a set of securitised debt instruments needs to know the two are not one dataset. This comparison sets them side by side. It is not investment advice.
Definition
Annexure I and Annexure II
are the two half-yearly SDI disclosure formats. Annexure I applies to securitisations of loans, listed debt securities or credit facility exposures. Annexure II applies to securitisations of other exposures. Both are filed by the trustee within 30 days of the end of March or September. Source: SEBI circular dated 16 December 2025.
Which format does a deal file?
Annexure I is headed "securitisation of loan / listed debt securities / credit facility exposures". Annexure II is headed "securitisation of other exposures". The permitted underlyings in the SDI Regulations include equipment leasing receivables, trade receivables arising from accepted bills or invoices, and rental receivables, alongside loans and listed debt securities, so the second format carries the receivables-backed side of the market.
Both start with the same identifier line: the name or identification number of the securitisation transaction.
SDI Annexure I vs Annexure II, head by head
| Head | Annexure I | Annexure II |
|---|---|---|
| Maturity characteristics | Weighted average maturity plus a four-bucket maturity distribution | Weighted average maturity only |
| Minimum retention requirement | Required, actual, and types of retained exposure | Identical, all three |
| Credit quality | Fourteen sub-items | Six sub-items |
| Overdue buckets | Up to 30, 31 to 60, 61 to 90, over 90 days | 0 to 30, 31 to 60, 61 to 90, over 90 days, framed as deviations against projected cashflows |
| Security cover and tangible security | Yes, named security by security | Not reported |
| Rating distribution and weighted average rating | Yes | Not reported |
| Historical default, upgradation, recovery and loss rates | Yes, five-year averages | Not reported |
| LTV and DTI distributions | Yes | Not reported |
| Obligor concentration | Not a reported field | Yes, any default by an obligor owing more than 10 percent of total receivables |
| Prepayment | Current portfolio, similar past portfolios, fees collected | Current portfolio only |
| Top-up and additional loans | Yes, two counts | Not reported |
| Expected credit loss | Yes | Not reported |
| Amendments | Documentation and payment terms, two counts | Identical, two counts |
| Industry and state-wise distribution | Yes | Not reported |
| Originator-level material events | Not a reported field | Yes |
| Minimum holding period | Required per RBI guidelines, plus weighted average and range | Required per SEBI guidelines, plus weighted average and range |
14 vs 6
Credit-quality sub-items in SDI Annexure I compared with Annexure II
Source: SEBI circular HO/17/11/18(1)2025-DDHS-POD1/I/342/2025 dated 16 December 2025
What the asymmetry actually means
Three consequences follow, and they are practical rather than academic.
These are not comparable datasets. More than half of Annexure I's analytical content has no counterpart in Annexure II. Stacking both into one table produces a schema where rating, LTV, DTI, expected credit loss, security cover, historical default rates and geography are null for every receivables-backed deal. Those nulls are not missing data. They were never required.
The same field name points at two rulebooks. The minimum holding period line reads "MHP required as per RBI guidelines" in Annexure I and "MHP required as per SEBI guidelines" in Annexure II. A consolidated view has to carry which regime produced the number, or the column silently mixes two standards. SEBI's own holding-period rule now sits in Regulation 30C, covered in what is the minimum holding period.
Concentration is measured on only one side. Annexure II asks specifically about any default by an underlying obligor who owes more than 10 percent of total receivables, or any material adverse change affecting that obligor. Annexure I has no equivalent single-name trigger. That reflects the shape of the risk: a receivables pool can be dominated by a handful of counterparties, while a retail loan pool is diffuse by construction. The issuance-stage cap in Regulation 19A, which bars any obligor from holding more than 25 percent of the pool, applies to both.
Where the two formats do agree
Four blocks are effectively identical, and they are the ones worth comparing across every deal:
- The retention block. Required MRR, actual retention, and the composition of the retained exposure, on the same base in both formats. The rule is set out in what is the minimum retention requirement.
- The amendments block. How many underlying transactions had documentation amended after securitisation, and how many had payment terms amended.
- Utilisation of credit enhancement and liquidity facility. Annexure I splits enhancement six ways including excess interest spread and subordination; Annexure II splits it four ways. Both ask whether the liquidity facility has been drawn.
- The servicing-default line. Both ask about defaults observed in collection and servicing functions discharged on behalf of the securitisation trust.
Those four survive any consolidation, which makes them the sensible spine for reading across deals.
Reading either one
The field-level walkthrough, including the inverted rating scale and the trailing default-rate average, is in how to read an SDI disclosure. For what the instrument is and who may buy it, see what is a securitised debt instrument, and for the trust that files these, see what is a special purpose distinct entity.
Two formats, one deadline, very different depth. The practical rule is to carry which annexure a number came from, so a receivables-backed pool is never read as though it disclosed what a loan-backed one did. Flock reports public regulatory filings with each claim sourced and dated, and takes no view on any instrument.
Frequently asked questions
What is the difference between Annexure I and Annexure II of the SDI disclosure?
Annexure I is the format for securitised debt instruments backed by loans, listed debt securities or credit facility exposures. Annexure II is the format for SDIs backed by other exposures, such as trade, rental or lease receivables. Annexure I carries far more credit-quality fields. Source: SEBI circular dated 16 December 2025.
Does Annexure II report loan to value and debt to income?
No. LTV and DTI distributions, rating-wise distribution, weighted average rating, historical default rates and upgradation or recovery rates appear only in Annexure I. Annexure II reports overdue buckets, obligor concentration, prepayment rate, recovery actions and enhancement utilisation. Source: SEBI circular dated 16 December 2025.
Why does Annexure I cite RBI for the minimum holding period and Annexure II cite SEBI?
Annexure I covers pools originated largely by RBI-regulated lenders, so its minimum holding period line reads MHP required as per RBI guidelines. Annexure II's equivalent line reads MHP required as per SEBI guidelines. The field name is identical in both formats but the governing rulebook differs. Source: SEBI circular dated 16 December 2025.
Do both SDI formats have the same filing deadline?
Yes. Both are filed by the trustee of the special purpose distinct entity to SEBI and to the stock exchange where the SDIs are listed, half-yearly, within 30 days from the end of March or September, effective 31 March 2026. Only the contents differ. Source: SEBI circular dated 16 December 2025.
Flock tracks these filings, sourced, dated, and linked back to the original. See what smart-money entities disclosed, without the guesswork about what it means.
Disclosures shown are public regulatory filings. Data may be delayed or incomplete. Smart-money entities may no longer hold positions shown. Not investment advice.