What does Regulation 46(1) say?
The rule is short. The company "shall maintain a functional website" with the basic information about the company. The regulation does not say what functional means. It gives no uptime figure. We found no SEBI definition of uptime in the regulation text. We did not check the SEBI Master Circular.
In plain terms, the site must work and must carry the basic facts about the company. A site that is down, or a page with an error, is the first thing an investor or an auditor will notice.
The 30 items under Regulation 46(2)
Regulation 46(2) says the company shall put the following information "under a separate section on its website". The words "under a separate section" have applied since 1 April 2019. The table lists each clause in plain words. Clause letters are as printed in the regulation, which has (a) to (z) plus (aa), (ab), (oa) and (za).
| Clause | What must be on the website | Timing or note |
|---|---|---|
| (a) | Details of the company's business. | |
| (aa) | Memorandum and Articles of Association. | Added 13 Dec 2024. |
| (ab) | A short profile of each director, with their directorships and full-time positions in companies. | Added 13 Dec 2024. |
| (b) | Terms and conditions of appointment of independent directors. | |
| (c) | Who sits on each committee of the board. | |
| (d) | Code of conduct for directors and senior management. | |
| (e) | The vigil mechanism or whistle blower policy and how it works. | |
| (f) | How non-executive directors are paid, if the annual report does not say. | |
| (g) | Policy on related party transactions. | |
| (h) | Policy for deciding which subsidiaries are material. | |
| (i) | Familiarisation programmes for independent directors: how many and for how long. | During the year and so far in total. |
| (j) | The email address for grievance redressal, and other details. | |
| (k) | Contact details of the officials who handle investor grievances. | |
| (l) | Financial information: the notice of the board meeting on results, the results once approved, and the full annual report. | |
| (m) | Shareholding pattern. | |
| (n) | Details of agreements with media companies or their associates. | |
| (o) | The schedule of analyst or investor meets, and the slides for those meets and for earnings calls. | Schedule at least two working days ahead, not counting the day of notice or the meet. Presentations before the event begins. |
| (oa) | Audio recordings, video recordings if any, and transcripts of post-earnings or quarterly calls. | Audio before the next trading day or within 24 hours, whichever is earlier. Video within 48 hours. Transcript within 5 working days. Audio and video stay up for at least 2 years, transcripts for at least 5. |
| (p) | The new name and the old name after a name change. | For one continuous year from the last change. |
| (q) | The items in Regulation 47(1), the newspaper advertisement of results. | |
| (r) | All credit ratings for outstanding instruments. | Updated immediately when a rating is revised. |
| (s) | Separate audited financial statements of each subsidiary. | Uploaded at least 21 days before the annual general meeting. A proviso covers foreign subsidiaries. |
| (t) | Secretarial compliance report. | Under Regulation 24A(2). |
| (u) | Policy for deciding the materiality of events or information. | Under Regulation 30(4)(ii). |
| (v) | Contact details of the senior officers who decide what is material and report it to the exchanges. | Under Regulation 30(5). |
| (w) | Disclosures under Regulation 30(8). | |
| (x) | Statements of deviation or variation. | Under Regulation 32. |
| (y) | Dividend distribution policy. | Under Regulation 43A(1). |
| (z) | Annual return under section 92 of the Companies Act, 2013. | |
| (za) | Employee Benefit Scheme documents, leaving out commercial secrets. | Added 13 Dec 2024. The board must approve any redaction. |
Since 13 December 2024 a company can give the exact link to the stock exchange page where the information is already available. That meets 46(2). Many companies still keep a copy on their own site, because investors look there first.
How fast must the website be updated?
Regulation 46(3) has two parts. First, the company "shall ensure that the contents of the website are correct." Second, it shall update any change in the content "within two working days from the date of such change in content."
The clock starts on the date of the change, not the date someone notices it. A new director, a changed contact person, a revised rating or a new policy all start the two days. Some items have their own, faster clocks, such as the call recordings and the rating revision, which are in the table.
Does the website need an Investors section?
The regulation asks for "a separate section". It does not name it, and the word "Investors" does not appear in Regulation 46. Most companies use an Investors or Investor Relations section because investors look for it. What matters is that all 30 items sit together and are easy to find from the home page.
Who is exempt from some items?
Regulation 15(2)(a) lifts some duties for small listed companies. Clauses (b) to (i) and (t) of Regulation 46(2) do not apply if paid-up equity share capital is not above Rs 10 crore and net worth is not above Rs 25 crore. The test uses the last day of the previous financial year. If a company later crosses the limits, it must comply within six months. The duties then keep applying.
Regulation 46(1), Regulation 46(3) and the other clauses of 46(2) are not in that list. Read Regulation 15(2) in full before you rely on the exemption, as it has other cases too.
What else does the regulation say about keeping information online?
- Regulation 30(8): disclosures made to the exchanges under Regulation 30 must also be on the website. The regulation text asks for at least five years, then the archival policy.
- Regulation 9: the company needs a board-approved policy for preserving documents. The hosting periods for call recordings point back to it.
- Regulation 62 is the matching rule for entities whose non-convertible securities are listed. We did not read it in detail, so check it if that is your case.
Common slips on listed company websites
These are our own observations from how corporate sites are built and kept. They are not findings from SEBI or from any named company.
- A page for a policy exists, but it links to an old version or to a file that no longer opens.
- The two working day rule is nobody's job, so changes wait for the next website release.
- Documents are uploaded as scanned images that cannot be searched or read on a phone.
- The grievance email address or the officer's phone number is out of date after a change of people.
- Call recordings and transcripts go up late, or are removed before the hosting period ends.
- The mobile version hides the investor section, or the menu does not reach it.
- Nobody checks the site at night or on a holiday, so a fault is found only when someone writes in.
A simple routine, in our own framing
This is a practical way to run the rule. It is our suggestion, not a SEBI requirement.
- Make one list: the 30 items, the page where each sits, the person who owns it and the date of the last update.
- Give the company secretary's team a simple way to send each change to the web team, with the date of the change.
- Count two working days from that date and put the new version up before it ends. Note the date in the list.
- Check every link in the investor section once a month, and after every release.
- Watch the website for downtime, and agree who is told and how fast someone answers when it fails.
- Keep recordings and transcripts for the periods in the table, and note when each may come down.
How PromotEdge fits
PromotEdge builds websites and looks after them after launch. Our website maintenance covers uptime alerts, backups, security and fresh content. We agree in writing who answers and how fast. See our work for IPO-listed companies and in website design and development. We are not a law firm. Your company secretary or lawyer decides what the regulation requires.
