SEBI introduces Framework for Issuance of Subordinate Units

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On 27-5-2024, the Securities and Exchange Board of India notified the Securities and Exchange Board of India (Infrastructure Investment Trusts) (Amendment) Regulations, 2024 to amend the . The provisions came into force on 27-5-2024.

The amendment inserts Chapter IVA relating to Framework for Issuance of Subordinate Units.

Key Points:


  1. Applicability- apply only to subordinate units issued after this chapter has been notified.


  2. Issuance of Subordinate Units-

    • Can be issued only by a privately placed InvIT upon acquisition of an infrastructure project.


    • Can be issued only to sponsor, its associates and the sponsor group and it will be a part of the consideration for acquisition of the infrastructure project.


    • These units will not carry any voting rights or distribution rights.


    • These units will be issued in a dematerialized form with an International Securities Identification Number.

  3. Transfer of Subordinate Units-

    • These units will be locked in till its reclassification into ordinary units.


    • It can be transferred only to sponsor/ its associates and sponsor group entities.

  4. Entitlement date/ event and performance benchmark-

    • Entitlement date, the entitlement event and the performance benchmark for reclassification of subordinate units to ordinary units shall be clearly defined and specified in the Term Sheet.


    • The performance benchmark should be quantifiable, objective and based on the audited financial statements.


    • Minimum time period between issuance of subordinate unit and entitlement date for reclassification will be 3 years.

  5. Progress related to achievement of performance benchmark-

    • Investment manager will monitor the progress and report it annually after obtaining certificate by statutory auditor og InvIT and approval of the trustee and the audit committee.


    • Th progress will be disclosed in the Annual Report of InvIT by the investment manager.

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