Sunil Industries reports partial non-compliance in dematerialization

Sunil Industries Limited filed its Annual Secretarial Compliance Report for the financial year ended March 31, 2026, confirming adherence to most SEBI regulations while noting a specific deviation regarding the dematerialization of promoter shareholdings. The report, submitted by HSPN & Associates LLP, highlights that 39,900 equity shares, representing 1.63% of the entire promoter shareholding, are yet to be dematerialized.

The review conducted by Hemant Shetye, Designated Partner of HSPN & Associates LLP, covered the compliance of the listed entity with various statutory provisions including the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and the SEBI (Prohibition of Insider Trading) Regulations, 2015. The report indicates that the company has complied with the provisions of the examined regulations and circulars, except for the matter concerning the physical shareholding of the promoter group.

Compliance Status and Observations

The report details the specific non-compliance under Regulation 31(2) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015. This regulation mandates that 100% of the shareholding of promoters and the promoter group must be in dematerialized form and maintained on a continuous basis. The company stated that the physical shares constitute a miniscule value and management is in the process of communicating with shareholders to dematerialize the shares.

Sr No	Compliance Requirement	Deviations	Observations / Remarks
1	Regulation 31(2) of SEBI LODR Regulations, 2015	Hundred percent Shareholding of promoter group was not in dematerialized form.	39,900 Equity shares constituting 1.63% of entire promoter shareholding is yet to be dematerialized.

Remedial Actions and Historical Context

The report outlines actions taken to address observations from previous financial years. For the financial year 2024-2025, the company dematerialized 1,000 equity shares, with the remaining shares still in process. In the financial year 2023-2024, the company dematerialized 1,400 equity shares out of a similar holding that was pending conversion at the time.

Financial Year	Shares Dematerialized	Pending Shares	Percentage of Total Holding
2024-2025	1,000	39,900	1.63%
2023-2024	1,400	40,900	0.98%

General Compliance Confirmation

Beyond the specific deviation, the report confirms that Sunil Industries Limited has complied with various other regulatory requirements. These include the adoption and timely updation of policies, maintenance of disclosures on the website, and performance evaluation of the Board and committees. The company also confirmed that no actions were taken against it, its promoters, or directors by SEBI or stock exchanges during the reporting period. Additionally, there were no resignations of statutory auditors, and no additional non-compliances were observed.

1 Day	5 Days	1 Month	6 Months	1 Year	5 Years
0.0%	+13.34%	-2.81%	+2.59%	+10.43%	+383.14%

Sunil Industries Limited has submitted its quarterly compliance certificate to the Bombay Stock Exchange, fulfilling regulatory requirements under SEBI's depositories regulations. The filing demonstrates the company's adherence to mandatory reporting standards for publicly listed entities.

Regulatory Compliance Filing

The company filed its certificate under Regulation 74(5) of SEBI (Depositories and Participants) Regulations, 2018 for the quarter ended March 31, 2026. Company Secretary and Compliance Officer Sourabh Sahu submitted the document to the Department of Corporate Service at Bombay Stock Exchange on April 8, 2026.

Filing Details:	Information
Quarter Ended:	March 31, 2026
Filing Date:	April 8, 2026
Scrip Code:	521232
Filed By:	Sourabh Sahu, Company Secretary
Membership No.:	ACS 55322

Registrar Confirmation

MUFG Intime India Private Limited, formerly known as Link Intime India Pvt. Ltd., serves as the company's registrar and share transfer agent. The registrar provided comprehensive confirmation regarding dematerialisation processes handled during the quarter.

Ashok Shetty, Sr. Vice President-Corporate Registry at MUFG Intime India, confirmed that all securities received from depository participants for dematerialisation during the quarter were properly processed. The registrar verified that securities were either accepted or rejected according to established procedures.

Dematerialisation Process Compliance

The registrar's certificate outlined several key compliance areas that were successfully managed during the quarter:

Securities received for dematerialisation were confirmed within prescribed timelines
All security certificates were properly mutilated and cancelled after due verification
Depositories' names were substituted in the register of members as registered owners
Securities comprised in certificates have been listed on stock exchanges where earlier issued securities are listed

Process Element:	Status
Securities Processing:	Confirmed/Rejected as per procedures
Certificate Handling:	Mutilated and cancelled after verification
Register Updates:	Completed within prescribed timelines
Exchange Listing:	Maintained on existing exchanges

Corporate Information

Sunil Industries Limited operates as an ISO 9001 & 14001 certified company with its corporate office located at 315, Rewa Chambers, New Marine Lines, Mumbai. The company maintains its registration under CIN No.: L99999MH1976PLC019331, reflecting its incorporation in Maharashtra in 1976.

The quarterly filing represents standard regulatory compliance for publicly listed companies, ensuring transparency in share transfer and dematerialisation processes. This certification provides stakeholders with assurance regarding proper handling of securities transactions during the reporting period.