How unlisted-share trades on Polemarch comply with SEBI.

Unlisted equity shares in India are securities under the Securities Contracts (Regulation) Act 1956, administered by SEBI. Their dematerialised form sits in one of two depositories — CDSL or NSDL — both registered under the Depositories Act 1996.

Every transfer between two demat accounts must cite the security's ISIN (International Securities Identification Number) on a DIS (Delivery Instruction Slip), signed by the seller and executed through their DP (Depository Participant — in practice, their broker).

Polemarch operates within this framework — we don't sit beside it. Every trade uses the standard DP-to-DP off-market pipe; we only coordinate the match and the funds flow.

SEBI's KRA (KYC Registration Agency) framework requires every investor to have verified PAN, Aadhaar, address, and bank proof on record before making a transaction in any regulated security — listed or unlisted.

We route each of these verifications through a SEBI-authorised verification partner. PAN and Aadhaar are matched directly against the UIDAI / NSDL records. Bank accounts are penny-drop verified. CMR uploads are matched against depository records before a demat is accepted.

Name-on-PAN must match your account holder name for transactions to clear. If it doesn't, our KYC flow surfaces the PAN holder name and lets you update your account — we can't let trades clear under a name mismatch.

Off-market equity transfers attract stamp duty at 0.015%of the transaction value, collected by the seller's DP at the time of DIS execution (per the Indian Stamp (Collection of Stamp-Duty through Stock Exchanges, Clearing Corporations and Depositories) Rules 2019).

Polemarch computes the stamp duty on the verified consideration and surfaces it on every invoice. No hidden line item.

Pre-IPO buyers should be aware of SEBI's post-listing lock-in regime (ICDR Regulations, Regulation 62):

• Shares held by promoters may be locked for 18 months from listing (varies).
• Shares held by non-promoters acquired within 6 months of filing the DRHP are typically locked for 6 months from listing.

Shares you buy on Polemarch are almost always the second category; the lock expires six months post-listing and you can sell freely on exchange after that. Share pages flag known lock-in windows explicitly.

SEBI's framework provides investor-protection primitives (SCORES grievance redress, SEBI Investor Charter, compulsory depository settlement) which we map to the platform directly:

• All holdings settle in your own demat, controlled by your DP — Polemarch never holds customer securities.
• Customer funds flow into per-customer virtual accounts at our payment partner — not into a Polemarch pooled operational account.
• Our risk disclaimer is surfaced on every share page, not buried in a T&C block.