What is a Structured Digital Database (SDD)?

A Structured Digital Database (SDD) is the tamper-proof digital log of unpublished price sensitive information (UPSI) and the people it is shared with. Regulation 3(5) of the SEBI (Prohibition of Insider Trading) Regulations, 2015, in the consolidation amended up to 12 March 2025 (read on 21 September 2026), puts the duty on "the board of directors or head(s) of the organisation of every person required to handle unpublished price sensitive information", which is wider than listed companies and intermediaries. This guide explains what a Structured Digital Database is, what it records, who has to keep one and how long it must be kept. It is not investment advice.

What does a Structured Digital Database record?

Regulation 3(5) names the contents. The database must contain the nature of the unpublished price sensitive information, the names of the persons who shared it, and the names of the persons with whom it was shared, in each case "along with the Permanent Account Number or any other identifier authorized by law where Permanent Account Number is not available".

Three design constraints follow in the same sub-regulation:

• Not outsourced. The database "shall not be outsourced and shall be maintained internally". This was added by the 2020 amendment, effective 17 July 2020; the pre-2020 text had no such bar.
• Non-tamperable, with checks. SEBI requires "adequate internal controls and checks such as time stamping and audit trails to ensure non-tampering of the database".
• A two calendar day clock for inbound UPSI. A proviso allows entry of information "not emanating from within the organisation" to be made not later than 2 calendar days from receipt. Information generated inside the organisation carries no such grace period on the face of the proviso.

Because entries cannot be quietly changed, the SDD is meant to give SEBI a reliable trail if it needs to reconstruct how sensitive information moved before a public announcement.

Which regulation requires an SDD?

The requirement sits in Regulation 3(5) of the SEBI (Prohibition of Insider Trading) Regulations, 2015. Note who it binds: "the board of directors or head(s) of the organisation of every person required to handle unpublished price sensitive information". The duty follows the handling of UPSI, not a registration category, so it reaches well beyond the issuer. Regulation 3(6) sets the retention period.

There is a second, near-identical pair of provisions for mutual funds. Chapter IIA of the same regulations, which governs insider trading in the units of a scheme, repeats the obligation at Regulation 5C(6) and the eight year retention at Regulation 5C(7), in the same words. An AMC handling UPSI about a scheme is inside the SDD regime on that footing, not on Regulation 3(5).

How long must an SDD be kept?

Under Regulation 3(6), the database must be preserved for eight years after the relevant transactions are completed.

If SEBI opens an investigation or enforcement proceeding, the relevant records must be kept until those proceedings finish, in addition to the eight years.

Where the SDD sits in insider-trading compliance

The SDD is the record behind the rules retail investors see the results of. The information it tracks is UPSI, and the trades that follow once information is public are reported through insider trading disclosure. During sensitive periods, designated persons are also blocked from trading under a trading window closure. When the underlying event finally goes public, it lands as a material event disclosure on the exchanges.

Flock reads disclosure filings and keeps each one dated and linked back to its source, so you can go from a summary to the original disclosure in one step. What any of it means for your money is your call to make.