SEBI received an informal guidance request from Ananya Finance for Inclusive Growth Private Limited under the SEBI (Informal Guidance) Scheme, 2025, concerning Regulation 62A of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021. Regulation 62A governs continuous listing obligations for issuers of non-convertible securities. The scheme allows market participants to seek SEBI's interpretive clarity on regulatory provisions without initiating formal enforcement, providing legal certainty before undertaking capital market transactions.

The SEBI (Informal Guidance) Scheme, 2025 is a structured mechanism that allows listed entities, intermediaries, and market participants to seek non-binding written clarifications from SEBI on specific provisions of securities laws — before they act. It is modelled on similar frameworks used by the US SEC (no-action letters). The key distinction: guidance issued is entity-specific, non-precedential, and not legally binding on SEBI in any subsequent enforcement action.

Ananya Finance for Inclusive Growth Private Limited is an NBFC focused on microfinance and financial inclusion. Its query relates to Regulation 62A of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021, which was introduced to impose continuous disclosure and compliance obligations on issuers of listed NCDs and other non-convertible instruments — similar to what Regulation 17 to 27 do for equity-listed companies under LODR.

This is significant because many smaller NBFCs and HFCs raise debt capital through listed NCDs but often find compliance thresholds ambiguous — especially around financial reporting timelines, material event disclosures, and trustee interaction obligations. By using the informal guidance route, Ananya Finance sought interpretive certainty without risking inadvertent non-compliance and the associated regulatory action. For SEBI Grade A aspirants, this tests knowledge of the interplay between SEBI's regulatory architecture, NCS Regulations, and the quasi-adjudicatory guidance mechanism.