Special Window for Physical Securities: SEBI 2026

The special window for physical securities is a one-year opening SEBI created for investors holding share certificates they bought before April 2019 but never got registered in their name. It runs from 5 February 2026 to 4 February 2027. Outside a window like this, a transfer deed executed before April 2019 has nowhere to go, because SEBI closed transfer of securities in physical form from that date. The rules are at para 17 of the Master Circular for Registrars to an Issue and Share Transfer Agents dated 6 February 2026.

What the special window for physical securities covers, and when

This is the second such window in short succession. Para 17.1 records that a special window for re-lodgement of transfer deeds of physical securities was opened by circular dated 2 July 2025. Para 17.2 states that the Board then decided to open another window, this time for both transfer and dematerialisation of physical securities sold or purchased before 1 April 2019.

Para 17.4 extends it to transfer requests that were submitted earlier and were rejected, returned or not attended to because of a deficiency in the documents or the process, or otherwise. A previous rejection is not a bar.

The eligibility matrix, and the one thing it turns on

Para 17.6 sets out a four-row matrix. Reading it, the deciding factor is not whether the deed was lodged before April 2019 but whether the original certificate still exists.

Both eligible rows require the original security certificate. Both ineligible rows are the cases where it is missing. If you are holding a deed but not the certificate, this window does not help; the replacement route is a duplicate-certificate service request, whose output is a letter of confirmation that has to be dematerialised within 120 days or the shares move to a suspense escrow demat account.

Two further exclusions sit outside the matrix. Para 17.8 keeps out cases involving disputes between transferor and transferee, which must be settled through the court or NCLT process. Para 17.9 excludes securities that have already been transferred to the Investor Education and Protection Fund.

What the transferee has to file

Para 17.7 lists six mandatory items:

1. Original security certificates.
2. The transfer deed executed prior to 1 April 2019.
3. Proof of purchase by the transferee, as may be available.
4. KYC documents of the transferee, per the ISR forms.
5. A latest client master list of the transferee's demat account, not older than two months, duly attested by the depository participant.
6. An undertaking cum indemnity in the format at Annexure 7 of the master circular.

The client master list requirement follows from the outcome: para 17.5 requires that securities so transferred be credited to the transferee only in demat mode. A physical certificate cannot come out the other side.

The one-year lock-in

This is the condition most likely to catch someone out. Under para 17.5, securities transferred through the window are under lock-in for one year from the date of registration of transfer, and during that period cannot be transferred, lien-marked or pledged.

So a transfer registered in, say, March 2026 produces a demat holding that is yours in every respect except that it cannot move until March 2027. The lock-in is a fraud control on a window that deliberately relaxes the ordinary documentation standard, not a penalty.

What the company and the RTA must do

Para 17.10 puts obligations on the other side too, and they are worth knowing because they set the timeline you should expect:

• Identity verification is mandatory for PAN, identity proof and address proof of both transferee and transferor. A name mismatch against the PAN card can be cured with an officially valid document or a gazette notification about the name change.
• Signature verification follows the procedure in Para (B) of Schedule VII of the LODR Regulations where the transferor's signature differs or is unavailable.
• Where the transferor cannot be reached, whether through non-delivery of the objection memo, non-cooperation, inability, non-traceability or a missing document, an advertisement must be published in one English national daily with nationwide circulation and one regional language daily published where the transferor was last known to live, giving 30 days for objections. A copy goes on the company's website, only a minimal fee may be charged to the investor for it, and the transfer can be effected only after those 30 days expire.
• If the transferee has died, the legal heirs can claim the securities under the specified transmission procedure.

That advertisement route is why a clean case and a hard case have very different timelines under the same window.

Where to start

Find the registrar first. A lodgement under the special window for physical securities is processed by the RTA, and checking your RTA and folio details identifies who that is and what they already hold on record for the folio. From there:

• Dematerialisation of shares is the mandatory output format for anything transferred under this window.
• Transmission of securities is the separate route where a holder has died rather than sold.
• A qualified RTA is the service-standard tier the larger registrars sit in.
• SCORES 2.0 is the complaint route if a request stalls.

Flock reports the filings themselves, each stamped with its date and linked back to the exchange or regulator that published it. What any of it means for you is your call to make.