SEBI revised the limits on ISINs for privately placed debt on 7 October 2026. The general allowance is 17 identifiers maturing in a financial year, split between 12 plain-vanilla debt ISINs and five in specified special categories. Qualifying Section 54EC capital-gains debt issuers may use six additional ISINs.[2]
Correction, 29 October: this report now includes the separate allowance for issuers using only special categories, the full category list and the precise outstanding-debt basis for volume-linked additional ISINs.[2]
Category limits and exceptions
Rules in the 7 October circular
| Category or condition | Applicable treatment |
|---|---|
| Plain-vanilla debt | 12 ISINs maturing in a financial year, for secured or unsecured issuesSource 2 |
| Special categories | Five ISINs for structured or market-linked debt, floating-rate bonds, zero-coupon bonds and Tier II debt capitalSource 2 |
| Only special categories issued | Up to 12 ISINs maturing in a financial yearSource 2 |
| Section 54EC capital-gains issues | Six additional ISINs for qualifying issuersSource 2 |
| Excluded issues | Government of India-serviced debt/extra-budgetary resources and the specified ESG debt securitiesSource 2 |
The outstanding-debt test
Additional plain-vanilla capacity is linked to total outstanding debt across the 12 ISINs maturing in the relevant financial year. It is not a test of all new issuance during that year. The circular’s illustration allows 12 ISINs for ₹1–15,000 crore outstanding, 13 for ₹15,001–18,000 crore and 14 for ₹18,001–21,000 crore, with further capacity in ₹3,000 crore steps.[2]
Floating-rate bonds, zero-coupon bonds and Tier II debt capital issued before the circular are grandfathered. If that legacy count is five or more, further issuance in the special-category bucket must wait until maturities reduce the count below five. The grandfathering provision does not describe every earlier structured issue as exempt.[2]
Planning by maturity year
An issuer therefore needs to classify each instrument and its maturity year before assessing remaining capacity. A headline allowance of 17 is insufficient for an issuer close to a category ceiling, using the volume adjustment or relying on the special-only route. The circular takes immediate effect and leaves the other provisions of the chapter unchanged.[2]
The revision changes identifier capacity for private placements. It does not itself change the credit standing of the issuer or the contractual rights attached to a bond. For arrangers and depositories, its practical effect is on how issues can be scheduled, grouped and monitored within the applicable annual limits.[2]
Sources & further reading
- Review of ISIN provisions for privately placed debt securities Securities and Exchange Board of India · 7 Oct 2026 · Accessed 29 Oct 2026
- SEBI circular HO/17/11/24(8)2026-DDHS-POD1/I/23125/2026 — original PDF Securities and Exchange Board of India · 7 Oct 2026 · Accessed 29 Oct 2026