OnEMI Technology Solutions Submits Fair Disclosure Code for UPSI Under SEBI PIT Regulations
OnEMI Technology Solutions Limited has submitted its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information to BSE and NSE pursuant to Regulation 8(2) of SEBI PIT Regulations, filed by Company Secretary Shraddha Rajkumar Patangia on May 08, 2026. The Code, adopted by the Board and effective from the date of equity share listing, establishes a comprehensive framework covering prompt public disclosure, uniform dissemination, analyst interaction protocols, need-to-know access controls, and operating guidelines for legitimate UPSI sharing with detailed audit and governance requirements.

*this image is generated using AI for illustrative purposes only.
OnEMI Technology Solutions Limited (formerly known as OnEMI Technology Solutions Private Limited) has filed its Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information with BSE Limited and the National Stock Exchange of India Limited. The submission was made pursuant to Regulation 8(2) of the Securities and Exchange Board of India (Prohibition of Insider Trading) Regulations, 2015, as amended. The filing was signed and submitted by Shraddha Rajkumar Patangia, Company Secretary and Compliance Officer (Membership No.: A55210), on May 08, 2026.
Document Overview
The Code was adopted by the Board of Directors of the company and is effective from the date of listing of the equity shares on recognized stock exchanges. Key details of the document are outlined below:
| Parameter: | Details |
|---|---|
| Document Name: | Code of Practices and Procedures for Fair Disclosure of Unpublished Price Sensitive Information |
| Original Document Date: | March 01, 2026 |
| Approved By: | Board of Directors |
| Filed With: | BSE Limited and National Stock Exchange of India Limited |
| Filed By: | Shraddha Rajkumar Patangia, Company Secretary and Compliance Officer |
| Filing Date: | May 08, 2026 |
Key Provisions of the Code
The Code establishes a comprehensive framework for the handling and disclosure of Unpublished Price Sensitive Information (UPSI). Its core provisions cover the following areas:
- Prompt Public Disclosure: UPSI shall be disclosed to stock exchanges and disseminated promptly on a continuous basis as soon as credible and concrete information comes into being.
- Uniform Dissemination: UPSI shall be disseminated uniformly and universally to all stakeholders through stock exchanges and by posting on the company's official website at www.kisht.com , to avoid selective disclosure.
- Response to Regulatory Queries: Appropriate, fair, and prompt responses shall be submitted to all queries on news reports and requests for verification of market rumors received from regulatory authorities.
- Analyst and Institutional Investor Interactions: Only public information will be provided to analysts, research personnel, and institutional investors. Any UPSI inadvertently shared must be simultaneously made public at the earliest.
- Need-to-Know Basis: UPSI shall be disclosed only to those within the company who require the information to discharge their official duties or legal obligations, subject to Chinese walls.
- Legitimate Purpose Framework: Communication or procurement of UPSI is governed by Operating Guidelines for Determination of Legitimate Purpose, as detailed in Annexure A of the Code.
Role of the Chief Investor Relations Officer
The Code designates a Chief Investor Relations Officer (CIRO) as the primary officer responsible for dissemination of information and disclosure of UPSI. The CIRO is responsible for ensuring the company's compliance with continuous disclosure requirements under the Insider Trading Regulations. In the absence of a designated CIRO, the Compliance Officer assumes this role.
Operating Guidelines for UPSI Sharing
Annexure A of the Code sets out detailed Operating Guidelines for the determination of legitimate purpose and approval for sharing of UPSI. These guidelines cover sharing of UPSI in the ordinary course of business with partners, collaborators, lenders, distributors, customers, suppliers, merchant bankers, legal advisors, insolvency professionals, and other advisors or consultants. The guidelines specify the following process controls:
- Requests for sharing UPSI must specify the nature of the assignment, details of UPSI, and rationale for sharing.
- A digital database of all persons with whom UPSI is shared must be maintained with time-stamping and audit trails.
- A due notice must be served to every recipient of UPSI prior to sharing, in the format prescribed in Annexure I-A.
- Non-Disclosure Agreements (NDAs) may be required in exceptional circumstances.
- Information must be shared on a need-to-know basis and must not be used to circumvent the provisions of the SEBI (Prohibition of Insider Trading) Regulations, 2015.
- Any deviations from the process shall be reported to the Audit Committee, and exceptions must be approved by the Board of Directors.
- The guidelines are subject to annual review by the Audit Committee.
Policy Review and Governance
The Board of Directors reserves the power to review and amend the Code from time to time. All provisions of the Code are subject to revision in accordance with applicable laws as may be issued by relevant statutory, governmental, and regulatory authorities. In the event of any amendment, clarification, or circular issued by such authorities that is inconsistent with the Code, the regulatory directive shall prevail.
Source: None/Company/INE12F801023/fbbb07a00aeb4629.pdf
How will OnEMI Technology Solutions' transition from a private to a publicly listed company affect its competitive positioning in the buy-now-pay-later and EMI financing market in India?
What potential risks could arise if the company's UPSI management framework is tested during major corporate events such as fundraising rounds, mergers, or regulatory investigations post-listing?
How might SEBI's evolving insider trading regulations impact OnEMI's compliance obligations, and could stricter enforcement actions reshape governance practices across fintech IPO candidates?

























