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SEBI revises private-debt ISIN limits, including a separate 12-identifier special-issue route

The 7 October circular sets a general 12-plus-five maturity-year limit, with additional capacity linked to outstanding debt. Issuers using only the specified special categories have a different ceiling.

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

At a glance01

Rules in the 7 October circular

Rules in the 7 October circular
Category or conditionApplicable treatment
Plain-vanilla debt12 ISINs maturing in a financial year, for secured or unsecured issuesSource 2
Special categoriesFive ISINs for structured or market-linked debt, floating-rate bonds, zero-coupon bonds and Tier II debt capitalSource 2
Only special categories issuedUp to 12 ISINs maturing in a financial yearSource 2
Section 54EC capital-gains issuesSix additional ISINs for qualifying issuersSource 2
Excluded issuesGovernment 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]

Follow the evidence

Sources & further reading

  1. Review of ISIN provisions for privately placed debt securities Securities and Exchange Board of India · 7 Oct 2026 · Accessed 29 Oct 2026
  2. 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

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