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First identify which document is missing: an RTA or participant certificate needed to process a dematerialisation request, an issuer’s exchange filing, or only the public copy of a filing. The next step depends on that distinction. Issuers should check exchange and company disclosure records, then ask the RTA for the certificate and a written status; an investor with a pending demat request should contact the DP handling it and the issuer or RTA.
Identify what is missing
“Regulation 74(5) certificate” is used in related but distinct contexts. It may refer to a certificate involved in processing a dematerialisation request, or to an issuer’s quarterly certificate or disclosure. Before escalating, note the security, the demat request date or quarter concerned, and whether the gap is in processing, filing, or public availability.
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| Situation | What may be missing | First useful check or contact |
|---|---|---|
| Issuer or company secretary | The RTA’s certificate, the issuer’s exchange submission, or the publicly listed copy | Check the exchange filing portal and the issuer’s investor-relations disclosure page; contact the RTA if its certificate has not arrived. |
| Investor with pending dematerialisation | A processing step or certificate/confirmation associated with the request | Contact the DP that accepted the request, and ask the issuer or RTA which step remains outstanding. |
An issuer disclosure page may list these under quarterly dematerialisation certificates. For example, Mazagon Dock Shipbuilders’ disclosure page groups Regulation 74(5) certificates with quarter-ended disclosures. That illustrates one issuer’s publication practice; it does not establish a universal filing route or due date.
If you are handling the issuer’s filing
- Check the relevant records. Search the company’s exchange filing portal and investor-relations disclosure page for the security and quarter. Confirm whether the certificate was filed but is not visible on the company page, or whether the exchange filing itself appears to be outstanding.
- Ask the RTA in writing. Identify the quarter or demat request and ask whether the certificate has been issued, its issue date, when and how it was dispatched, and the reason for any delay. Retain the dated request and the response.
- File promptly once the required document is available. Keep the certificate, submission acknowledgement, and any exchange correspondence with the follow-up record. A company-specific secretarial compliance report describes filing after receipt of the certificate from the RTA on November 5, 2024; this shows a documented route in that case, not a safe harbour from enforcement or a universal process. See the company’s 2025 secretarial compliance report.
- Confirm the applicable obligation before stating a due date. Ask the company secretary or securities-law adviser to check the current SEBI text, the relevant exchange’s latest instructions, and the issuer’s specific status. Record the rule or exchange instruction relied on.
If your dematerialisation request is pending
Start with the DP that accepted the request, because it can identify the request and advise which processing step remains open. Provide the security and request date, and ask what is outstanding, who currently holds the next action, and whether the relevant certificate or confirmation has been issued. You can also contact the issuer or RTA to establish the status of any issuer-side step.
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SEBI’s circular connects Regulation 74(5) with issuer/RTA processing of demat requests, but the available material does not establish a complete current investor escalation timetable. Check current official guidance for the complaint route applicable to your specific case rather than assuming a fixed number of days for escalation.
How to interpret the deadline references
Do not treat every “15-day” reference as the same deadline. SEBI’s April 16, 2020 circular refers to an existing 15-day timeline for issuer/RTA processing of demat requests. Its provisions excluding dates and allowing for backlog were COVID-era measures, not evidence that the temporary relief remains available. Read the SEBI circular dated April 16, 2020 in that historical context.
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Separately, a 2025 secretarial compliance report describes an obligation for that listed entity to file the certificate with each exchange within 15 days of quarter-end. It reports a five-day delay attributed to non-receipt from the RTA. That is a company-specific account of a quarterly exchange filing; it should not be substituted for checking the controlling current requirement for another issuer or document. See the 2025 secretarial compliance report.
What a delay may mean
Secretarial reports show that delayed filings can be recorded as non-compliance and that an issuer may document non-receipt from its RTA as the reason. They do not establish a fixed automatic fine for every delay, nor do they guarantee that a particular delay will have no consequence. If the exchange has issued a notice or specific direction, follow that communication and obtain case-specific advice on the response.
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- Preserve dated RTA requests and replies, the certificate and receipt details, the filing acknowledgement, and exchange correspondence.
- Keep the reason for delay clear and factual; do not describe a temporary COVID-era relaxation as current relief without confirming a current authority.
- Use the applicable current SEBI text and exchange instructions to determine the deadline and any consequence for the specific obligation.
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