The SEBI Master Circular for Depositories, issued on December 3, 2024, outlined the process for generating CAS for securities and assets in investors’ accounts. According to the guidelines, CAS was to be generated on a monthly basis, and Asset Management Companies (AMCs) and Mutual Fund Registrar and Transfer Agents (MF-RTAs) were required to share common PAN data with depositories within three days of the month-end. Depositories, in turn, had ten days to consolidate the information and dispatch the CAS.
However, due to challenges in meeting these strict timelines and feedback received from depositories and MF-RTAs, SEBI has now revised these deadlines to ease compliance. The goal is to ensure a smoother process while still maintaining the integrity of the system.
Revised Timelines: Key Changes
Submission of Data by AMCs/MF-RTAs: The new timeline gives AMCs and MF-RTAs an extra two days to submit the common PAN data to depositories. Instead of the previous deadline of three days from the month-end, AMCs and MF-RTAs are now required to send the necessary data by the 5th day of the month following the month-end.
CAS Dispatch by Depositories: After receiving the data, depositories now have more time to consolidate and send out the CAS to investors:
For electronic delivery (e-CAS), the CAS must be dispatched by the 12th day of the month.
For physical delivery, depositories must send the CAS by the 15th day of the month.
Half-Yearly CAS: In addition to monthly CAS, there is a provision for half-yearly CAS. AMCs and MF-RTAs are required to send the common PAN data to depositories by the 8th day of April and October each year. Depositories, in turn, must dispatch:
e-CAS by the 18th day of April and October.
Physical CAS by the 21st day of April and October.
Transactions and No Transactions in Accounts: One of the significant updates is the provision regarding investors’ accounts with no transactions. If there are no transactions in either mutual fund or demat accounts, the CAS will still be sent to investors on a half-yearly basis, with withholding details included. If any transaction has taken place, CAS will be generated monthly.
Investor Preferences for Delivery Mode: Investors can opt to receive their CAS via electronic delivery or physical mode. If an investor does not wish to receive CAS via email, they can choose to have it sent in physical form to their registered address.
Effective Date and Compliance Requirements
The new timelines and changes will come into effect starting May 14, 2025. To ensure a smooth implementation, depositories are required to amend their bye-laws, rules, and regulations as necessary. They are also expected to make any required system changes to facilitate the revised process. Additionally, the depositories are instructed to update their websites to disseminate the details of the revised circular to all stakeholders.
