The High-Level Committee (HLC) established by the Securities and Exchange Board of India (SEBI) to assess conflict of interest and disclosure standards for its officials has delivered its report to SEBI Chairman Tuhin Kanta Pandey on Monday.
The six-member committee, chaired by former Chief Vigilance Commissioner Pratyush Sinha, was formed by SEBI’s board in March this year to conduct a thorough review of the current internal policies.
The panel includes notable figures such as Injeti Srinivas, former Secretary of the Ministry of Corporate Affairs; Uday Kotak, Founder and Director of Kotak Mahindra Bank; G. Mahalingam, former whole-time member of SEBI; Sarit Jafa, former Deputy Comptroller and Auditor General; and Prof. R. Narayanaswamy, a former professor at IIM Bangalore.
The committee was tasked with examining SEBI’s framework regarding conflict of interest, property and investment disclosures, and recusal procedures, with the goal of identifying gaps or ambiguities.
In addition, the committee was directed to recommend a robust mechanism for preventing, mitigating, and managing potential conflicts. This includes maintaining digital records and establishing a process that allows the public to lodge complaints about conflicts of interest or disclosure failures.
Expected recommendations from the committee may include stricter regulations on personal financial disclosures for SEBI officials and board members, possible limitations on direct equity investments, and clear guidelines for recusal in cases of potential conflicts. The committee might also suggest real-time tracking of disclosures and regular audits to ensure adherence, aligning with global best practices.
The report’s recommendations are anticipated to be submitted to SEBI’s board for consideration in December.
Published on November 10, 2025.






