Debenture trustee website disclosures: SEBI rules

Debenture trustee website disclosures are one of the few places where a bond investor can check an issuer's payment record without a data subscription. SEBI requires the trustee, not just the issuer, to publish. That includes an ISIN level calendar of what was due and what was actually paid, updated within a day of the due date, and the trustee's own minimum fee. This guide covers the eight prescribed tables, their deadlines, and the two disclosures that sit outside them. It is not investment advice.

What are the prescribed website disclosures?

Chapter VII of SEBI's Master Circular for Debenture Trustees, SEBI/HO/DDHS-PoD-1/P/CIR/2025/117 dated August 13, 2025, sets out a table of disclosures with a periodicity and a prescribed format for each. The formats are the numbered tables in Annex VIIA. The circular groups them into four periodicity bands.

The quarterly band follows the same 75 day rule, with the same year end exception, as the reports the trustee files with the stock exchange.

What do the tables actually contain?

The formats are specific enough to be useful, which is what makes this chapter worth reading rather than skimming.

Table 1, credit rating revisions, records the listed entity's name and ISIN, the immediate previous credit rating with its date and the rating agency, the revised rating with its agency and date of review, and a hyperlink to the rating agency's press release. The hyperlink requirement means the trail leads back to the primary document rather than stopping at the trustee's summary.

Table 2, payment status, records the due date of payment of interest or principal, the actual date of payment, and a status field with defined values including default, delayed, non cooperation and no information. It also records the date the trustee gave the information to the exchange, the date it gave the information to the credit rating agency, and details of any action the trustee took.

That status field is worth noting because it separates a missed payment from an information failure. Non cooperation and no information are distinct entries from default.

Table 3, monitoring of utilisation certificate and security cover, is the widest. It records the issue type as public or privately placed listed, issue size in rupees crore, whether the issue is secured or unsecured, and whether the listed entity submitted its periodical reports, quarterly compliance reports and financial statements, as a yes or no. On the utilisation certificate it records the date of receipt and any delay with reasons, including follow up done by the trustee. On security cover it records who provided the certificate, with the options being the debenture trustee, the statutory auditor or another party to be specified, the security cover ratio maintained, the date of the certificate, and any delay in submission with reasons and follow up.

Table 4, issues handled, is a half yearly roll forward: issues at the end of the last half year ended March or September, issues accepted during the half year, issues fully redeemed during the half year, issues outstanding on the last day of the half year, and cumulative issues handled up to that half year.

Does a debenture trustee have to publish its own fee?

Yes, and this is separate from the tables. Paragraph 2 requires the debenture trustee to disclose on its website the nature of the compensation arrangement with its clients, including the minimum fee to be charged, expressed either in absolute terms or as a percentage of the issue size, and the factors determining it.

The trustee is paid by the issuer whose compliance it polices, so publishing the fee basis puts that relationship on the record.

The ISIN level interest and redemption calendar

Paragraph 3 requires a calendar of interest and redemptions, due and paid, on the trustee's website for the financial year. It runs on three separate clocks.

The circular words the first as five working days and the second as five days, so they are not interchangeable.

The third row is the one that gives the calendar its value. Paragraph 3.3 requires the payment status to be updated no later than a day after the due date, and where the issuer paid late, the trustee updates the calendar specifying the date of that payment with the remark delayed payment. A late payment leaves a marked, dated entry rather than quietly resolving into a paid status.

Related reading

The exchange facing side of the same monitoring regime, including the reports a trustee files and the two working day alerts, is in debenture trustee reporting deadlines. The certificate that Table 3 tracks is explained in what is a security cover certificate. What Table 5 records, and the actions a trustee can take, is covered in what happens when a bond covenant is breached.

These disclosures are records of dates, statuses and documents published by trustees. Flock reports what issuers and trustees disclose, with the source and the date attached. It is not investment advice.