Country Club FY26 report notes gaps in PIT regulations
R&A Associates' secretarial compliance report for Country Club Hospitality & Holidays Limited for FY26 identified non-compliance with SEBI (Prohibition of Insider Trading) Regulations concerning the publication of the Code of Practices and the maintenance of a structured digital database. The audit also found deficiencies in website disclosures, including missing information under Regulation 46(2) and inaccurate web-links in corporate governance reports. No regulatory actions were reported against the company or its promoters.

*this image is generated using AI for illustrative purposes only.
A secretarial compliance audit for the financial year ended March 31, 2026, revealed that country club hospitality failed to ensure full compliance with specific SEBI regulations regarding insider trading and website disclosures. The report, issued by R&A Associates, highlighted that the Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information was not published on the company’s website in the prescribed manner. Additionally, the company lacked a structured digital database as required under Regulation 3(5) & 3(6) of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
The examination of documents and records for the review period indicated that while the company has adopted applicable policies under SEBI regulations with board approval, it fell short of maintaining conformity in certain areas. Specifically, certain disclosures required under Regulation 46(2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 were not available on the website. Furthermore, web-links provided in the annual corporate governance reports under Regulation 27(2) were found to be inaccurate and non-specific, failing to redirect users to the relevant documents or sections.
Compliance Status Overview
The audit covered various regulatory frameworks including the SEBI Act, 1992, the Securities Contracts (Regulation) Act, 1956, and the SEBI (LODR) Regulations, 2015. The following table summarizes the compliance status and observations recorded by the auditors:
| S.No | Particulars | Compliance Status | Observations |
|---|---|---|---|
| 1 | Secretarial Standards | Yes | Nil |
| 2 | Adoption and updation of Policies | No | Code of Practices for Fair Disclosure not published on website. |
| 3 | Maintenance and disclosures on Website | No | Disclosures under Reg 46(2) missing; web-links under Reg 27(2) inaccurate. |
| 4 | Disqualification of Director | Yes | Nil |
| 5 | Details related to Subsidiaries | Yes | Nil |
| 6 | Preservation of Documents | Yes | Nil |
| 7 | Performance Evaluation | Yes | Nil |
| 8 | Related Party Transactions | Yes | Nil |
| 9 | Disclosure of events or information | Yes | Nil |
| 10 | Prohibition of Insider Trading | No | Lack of structured digital database under Reg 3(5) & 3(6). |
| 11 | Actions taken by SEBI or Stock Exchanges | NA | Nil |
| 12 | Resignation of statutory auditors | NA | Nil |
| 13 | Additional Non-compliances | Yes | Nil |
Governance and Regulatory Findings
Regarding its subsidiary structure, the company stated it does not have any Material Subsidiary as defined under the LODR Regulations, with details of other subsidiaries disclosed in Form AOC-2. The report confirmed that none of the directors were disqualified under Section 164 of the Companies Act, 2013. The firm also noted that the listed entity conducted performance evaluations of the Board, Independent Directors, and Committees as prescribed.
R&A Associates clarified that the responsibility for compliance and authenticity of documents lies with the management, and their report is based solely on the examination of relevant documents. The report is neither an audit nor an expression of opinion on the financial records. It is intended specifically for compliance purposes under Regulation 24A(2) of the SEBI (LODR) Regulations, 2015, and does not assure the future viability of the company or the efficacy of its management.
Historical Stock Returns for Country Club Hospitality
| 1 Day | 5 Days | 1 Month | 6 Months | 1 Year | 5 Years |
|---|---|---|---|---|---|
| -3.93% | -2.12% | -6.30% | -18.50% | -19.01% | +117.65% |
What potential penalties or enforcement actions might SEBI impose for these specific insider trading and disclosure lapses?
How will the company establish the required structured digital database to ensure compliance with PIT Regulations moving forward?
What immediate steps is management taking to correct the inaccurate web-links and missing disclosures on the company website?





























