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COVID-19
LEGAL UPDATES
3rd Floor, Kalpataru Heritage,
127, M.G.Road,
Fort, Mumbai 400 001
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Table of Contents
Contents Page
1 INTRODUCTION ..................................................................................................................... 1
2 Relaxations under the CA 2013 ........................................................................................... 3
3 Relaxations under the IBC ................................................................................................... 5
4 Relaxations granted by SEBI ............................................................................................... 6
4.1 Relaxations under the LODR ..................................................................................... 6
4.2 Relaxations under the Takeover Regulations .......................................................... 7
4.3 Relaxation for listing of NCDs/NCRPS/CPs ............................................................. 7
4.4 Relaxations for REITs and InvITs .............................................................................. 7
4.5 Relaxations for Mutual Funds, AIFs, VCFs and AMCs ............................................ 7
4.6 Relaxations for FPIs, portfolio managers and CRAs .............................................. 8
5 Relaxations granted by the RBI ........................................................................................... 9
6 Relaxations granted by IRDAI ............................................................................................ 10
7 CONCLUSION ...................................................................................................................... 10
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1 INTRODUCTION
1.1 As a measure to curb the spread of coronavirus, India is now under a lockdown for 21 days starting from
midnight of 24 March 2020. This means that other than essential services (like healthcare facilities, food
supply, banks, pharmacies, post, etc.) all offices, schools, colleges, malls, restaurants, etc. must mandatorily
remain closed for this period.
1.2 Recognizing that it is not possible to conduct business in the ordinary course, the Government of India and
various regulators have granted relaxations from filing and other requirements under various laws and
regulations.
1.3 We have set out below some of the material relaxations under the Companies Act, 2013 (“CA 2013”), the
Insolvency and Bankruptcy Code (“IBC”), the Reserve Bank of India (“RBI”) regulatory framework, various
regulations issued by the Securities and Exchange Board of India (“SEBI”) and the Insurance Regulatory
and Development Authority of India are set out below.
1.3.1 CA 2013
(i) Extension of timeline – The timeline for filing declaration for commencement of business, and
the due date for creation of debenture redemption reserve and deposit repayment reserve has
been extended.
(ii) Directors and board meetings – (a) the requirement for companies to have at least one director
resident in India and for independent directors to have at least one meeting in the absence of
non-independent directors has been relaxed; (b) the maximum permissible time gap between
two board meetings has been extended; and (c) a relaxation has been provided in the matters
which can be dealt with in board meetings held through video conference or other audio visual
means.
(iii) Introduction of the Companies Fresh Start Scheme, 2020 (“Company Scheme”) and
modification of the LLP Scheme, 2020 (“LLP Scheme”) for allowing waiver of late fees for any
delay in filing of any e-forms with the Registrar of Companies between 1 April 2020 and 30
September 2020.
(iv) Clarification that any funds spent on COVID-19 activities would be counted towards CSR
activity.
(v) The Companies (Auditor’s Report) Order, 2020 to now be enforced from 1 April 2020.
1.3.2 IBC
(i) The monetary threshold for default under the IBC has been increased to INR 1,00,00,000 (Indian
Rupees one crore).
(ii) The period of lockdown imposed by the Government of India shall not be counted for the
purposes of the timeline for any activity required to be done under the Insolvency and
Bankruptcy Board of India (Insolvency Resolution Process for Corporate Persons) Regulations,
2016 (“CIRP Regulations”).
1.3.3 SEBI has provided the following relaxations:
(i) LODR – extension of the due dates for making various filings and disclosures under the SEBI
(Listing Obligations and Disclosure Requirements) Regulations, 2015 (“LODR”) (e.g.,
compliance certificate on share transfer facility, quarterly statement on investor complaints,
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annual secretarial compliance report, quarterly corporate governance report, shareholding
pattern, financial results, company secretary certificate on timely issuance of share certificates,
etc.);
(ii) annual general meeting – extension of the due date of the requirement under the LODR for the
top 100 listed companies by market capitalizations to hold the annual general meeting;
(iii) meetings of NRC and other committees – an extension of 3 months has been granted for
meeting the requirement under the LODR for the nomination and remuneration committee,
stakeholders relationship committee and risk management committee to hold at least one
meeting in a year;
(iv) an exemption has been granted from compliance of the requirement under the LODR of
publication of advertisements in newspapers for all events scheduled till 15 May 2020;
(v) the enforcement of the SEBI circular of 22 January 2020 on standard operating procedure on
imposition of fines and other enforcement actions for non-compliances under the LODR has
been extended;
(vi) disclosure of shareholding – extension of the due dates for making disclosures of shareholding
in listed companies by promoters and shareholders holding 25% or more shareholding/ voting
rights as per the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011
(“Takeover Regulations”);
(vii) extension of the date of issuance for non-convertible debentures (“NCDs”)/ non-convertible
redeemable preference shares (“NCRPS”)/ commercial papers (“CPs”) proposed to be listed on
or before 31 March 2020;
(viii) compliance by REITs and InvITs – extension of the due dates for making filings and disclosures
by Real Estate Investment Trusts (“REITs”) and Infrastructure Investment Trusts (“InvITs”)
under the SEBI (Real Estate Investment Trusts) Regulations, 2014 (“REIT Regulations”) and
the SEBI (Infrastructure Investment Trusts) Regulations, 2014 (“InvIT Regulations”);
(ix) mutual funds and AMCs – extension of the due dates for making filings and disclosures by
mutual funds under the SEBI (Mutual Funds) Regulations, 1996 (“MF Regulations”), extension
of one year for launching new mutual fund schemes and relaxation in access control measures
by asset management companies (“AMCs”);
(x) AIFs and VCFs – extension of the due dates for making regulatory filings by Alternative
Investment Funds (“AIFs”) and Venture Capital Funds (“VCFs”) under the SEBI (Alternative
Investment Funds) Regulations, 2012 (“AIF Regulations”);
(xi) extension of implementation of the Stewardship Code introduced by SEBI by its circular of 24
December 2019, for all mutual funds and all categories of AIFs;
(xii) FPIs – a relaxation has been provided in relation to the requirement under the SEBI (Foreign
Portfolio Investors) Regulations, 2019 (“FPI Regulations”) requiring applicant foreign portfolio
investors (“FPIs”) to submit original KYC documents or attested copies where originals are not
available;
(xiii) extension of timelines for monthly reporting to SEBI by portfolio managers, and extension of
implementation of the guidelines for portfolio managers issued by SEBI by its circular dated 13
February 2020; and
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(xiv) permitting credit rating agencies (“CRAs”) to not consider non-payment of principal/ interest or
any rescheduling of payment of debt obligation as a default. In addition, the timelines/ due dates
for filings/ disclosures required to be made by CRAs under the SEBI (Credit Rating Agencies)
Regulations, 1999 have been extended.
1.3.4 RBI – The RBI has permitted banks, all India financial institutions and non-banking financial companies
(together, the “Lending Institutions”):
(i) to declare a moratorium on payment of instalments falling due between 1 March 2020 to 31 May
2020 in relation to term loans and interest on working capital facilities availed of in the form of
cash credit or overdraft; and
(ii) to recalculate the drawing power of a borrower who has availed of working capital facilities in
the form of cash credit or overdraft and who is facing stress on its borrower account due to
COVD-19 by reducing the margins and/or by reassessing the working capital cycle until 31 May
2020.
The RBI has clarified that this will not lead to reclassification of assets in the books of the relevant
Lending Institution.
1.3.5 RBI – The RBI has granted an extension in the timeline for realisation of proceeds in relation to exports
of goods and services from India as required under the Foreign Exchange Management (Export of
Goods and Services) Regulations, 2015 (“Export Regulations”).
1.3.6 IRDAI – The IRDAI has granted the following relaxations:
(i) returns – extension of timeline for submitting monthly and quarterly returns by insurers and
insurance intermediaries;
(ii) extension to re-insurers for submission of their final re-insurance programme for the financial
year 2020-21; and
(iii) customers – grant of a grace period in payment of insurance premiums in relation to life/ health
insurance policies and continuation of current premium rates in respect of motor insurance
policies. A more detailed summary of these changes are set out in paragraphs 2 to 6 (both
inclusive) below.
2 Relaxations under the CA 2013
2.1 The following relaxations have been provided under the CA 2013:
2.1.1 Extension of timeline
CA 2013 section/ rule Requirement Relaxation
Declaration for
commencement of
business (Section 10A)
A company having a share capital which is
incorporated on or after 2 November 2018
cannot commence any business or exercise
any borrowing powers unless inter alia a
declaration is filed by a director within a period
of 180 days of the date of incorporation of the
company with the Registrar of Companies that
every subscriber to the memorandum has
paid the value of the shares agreed to be
The period of 180 days
available for filing the
declaration has been increased
to 360 days.
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CA 2013 section/ rule Requirement Relaxation
taken by him on the date of making of such
declaration.
Creation of debenture
redemption reserve
(Section 71 read with
Rule 18(7)(v) and
18(7)(vi) of the
Companies (Share
Capital and Debenture)
Rules, 2014)
Certain companies which have issued
secured debentures are required to invest by
30 April of each year at least 15% of the value
of debentures maturing in the next financial
year into prescribed investment options.
The due date for this
investment has been extended
to 30 June 2020.
Deposit payment
reserve (Section 73
read with Rule 13 of the
Companies
(Acceptance of
Deposits) Rules, 2014)
Companies which have accepted deposits
from the public or its members are required to
create a deposit repayment reserve by 30
April of each year of an amount equal to 20%
of the deposits maturing in the following
financial year.
The due date for creating this
reserve has been extended to
30 June 2020.
2.1.2 Directors and board meetings
CA 2013 section/ rule Requirement Relaxation
Director resident in
India (Section 149(3))
Every company is required to have at least
one director who is resident in India for at least
182 days in a financial year.
Exempted.
Meeting of
independent directors
(Section 149(8) read
with Schedule VI –
Code for Independent
Directors)
Independent directors of a company are
required to hold at least one meeting in a
financial year in the absence of the non-
independent directors.
Exempted.
Maximum time gap
between board
meetings (Section
173(1))
Board of directors of a company are required
to hold at least 4 meetings every year with not
more than 120 day gap between two
meetings.
The time gap of 120 days
between two board meetings
has been extended by 60 days
(i.e. total 180 days) for the next
two quarters i.e. till 30
September 2020.
Board matters which
can be dealt with via
video conference
(Sections 173, 177,
178 and 186 read with
Rule 4 of the
Companies (Meetings
The following matters cannot be dealt with in
a meeting of the board of directors of a
company through video conferencing or other
audio visual means:
approval of annual financial
statements;
approval of the Board’s report;
For the period beginning from
19 March 2020 and ending on
30 June 2020, these matters
may also be dealt with in a
board meeting through video
conference or other audio
visual means.
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of Board and its
Powers) Rules, 2014)
approval of the prospectus;
audit committee meetings for
consideration of financial statements
including consolidated financial
statements, if any, to be approved by
the Board under sub-section (1) of
section 134 of the Companies Act,
2013; and
approval of any matter relating to
amalgamation, merger, demerger,
acquisition and takeover.
2.2 The following relaxations have also been provided:
2.2.1 E-registry moratorium – The MCA has introduced the Companies Fresh Start Scheme, 2020 and has
modified the LLP Scheme, 2020 pursuant to which companies and limited liability partnerships may
regularize any historical defaults in filings regulatory e-forms required under the CA 2013. According
to these schemes, no late fees or penalties will be imposed for late filing of e-forms on the MCA21 e-
registry between 1 April 2020 and 30 September 2020 irrespective of the due date of filing the form.
However, the Company Scheme will not apply: (a) to companies which have applied for striking off or
obtaining dormant status or where action for striking off has already been initiated; (b) to companies
which have amalgamated into any other company; and/ or (c) in respect of e-forms for increase in
authorised share capital and charge creation/ satisfaction related e-forms. Similarly, the LLP Scheme
will also not apply to limited liability partnerships which have made applications for striking off.
2.2.2 Funds spent on COVID -19 activities – The MCA issued a notification on 23 March 2020 clarifying that
any funds spent by a company on various COVID-19 activities, including promotion of health care,
preventive health care and sanitation and disaster management and any contribution made to the PM
CARES Fund, would be counted towards the company’s CSR activity.
2.2.3 Disclosure of whistleblower complaints – The Companies (Auditor’s Report) Order, 2020 which
requires all companies to mandatorily disclose all whistleblower complaints to the auditor will now be
enforced in respect of audit of financial statements for financial years commencing on or after 1 April
2020 (instead of 1 April 2019).
3 Relaxations under the IBC
3.1 Minimum default threshold – The monetary threshold for default under the IBC is increased from INR
1,00,000 (Indian Rupees one lakh) to INR 1,00,00,000 (Indian Rupees one crore) to ensure protection for
MSMEs against forced insolvency.
3.2 Lockdown period excluded – The CIRP Regulations were amended on 29 March 2020 to provide that the
period of lockdown imposed by the Government of India will not be counted for the purposes of the timeline
for any activity that could not be completed due to such lockdown in relation to a corporate insolvency
resolution process.
3.3 Potential suspension of certain provisions – The Finance Minister announced on 24 March 2020 that if the
COVID-19 situation stays as is beyond 30 April 2020, the Government of India may consider suspending
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Sections 7, 9 and 10 of the IBC relating to initiation of corporate insolvency proceedings by financial creditors,
operational creditors and corporate applicants respectively, to avoid increasing insolvencies.
4 Relaxations granted by SEBI
4.1 Relaxations under the LODR
4.1.1 By its notifications of 19 March 2020, 23 March 2020 and 26 March 2020, SEBI has granted the
following relaxations in respect of compliances under the LODR:
Requirement Relaxation
Compliance certificate on
share transfer facility
(Regulation 7(3))
The due date for filing the half-yearly compliance certificate on share transfer
facility has been extended from 30 April 2020 to 31 May 2020.
Statement of investor
complaints (Regulation
13(3))
The due date for filing the quarterly statement of investor complaints has
been extended from 21 April 2020 to 15 May 2020.
Meetings of committees
(Regulations 19(3A), 20
(3A) and 21 (3A))
An extension of 3 months has been granted for meeting the requirement of
holding at least one meeting a year of the nomination and remuneration
committee, stakeholders’ relationship committee and risk management
committee. This requirement can now be met by 30 June 2020.
Secretarial compliance
report (Regulation 24A
read with circular dated 8
February 2019)
The due date for filing the annual secretarial compliance report has been
extended from 30 May 2020 to 30 June 2020.
Corporate governance
report (Regulation 27(2))
The due date for filing the quarterly corporate governance report has been
extended from 15 April 2020 to 15 May 2020.
Shareholding pattern
(Regulation 31)
The due date for filing the quarterly shareholding pattern has been extended
from 21 April 2020 to 15 May 2020.
Quarterly/ Annual financial
results (Regulation 33)
The due date for filing the quarterly financial results has been extended from
15 May 2020 to 30 June 2020.
The due date for filing the annual financial results has been extended from
30 May 2020 to 30 June 2020
Certificate on issuance of
share certificates
(Regulation 40(9))
The due date for filing the certificate from a practicing company secretary on
timely issuance of share certificates has been extended from 30 April 2020
to 31 May 2020.
Exemption for publication
of advertisements
(Regulation 47)
The requirement of publishing information such as notice of the board
meeting, financial results etc., in the newspapers has been exempted for all
events scheduled till May 15, 2020.
Holding AGMs of top 100
listed companies
(Regulation 44(5))
The due date for holding the annual general meetings of the top 100 listed
companies by market capitalization (determined as of 31 March of each
financial year) has been extended from 31 August 2020 to 30 September
2020.
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Requirement Relaxation
Half-yearly/ annual
financial results
(Regulations 52(1) and
52(2))
The due date for filing the half yearly financial results of companies which
have issued listed NCDs/ NCRPS/ CPs has been extended from 15 May
2020 to 30 June 2020.
The due date for filing the annual financial results of companies which have
issued listed NCDs/ NCRPS/ CPs has been extended from 30 May 2020 to
30 June 2020.
Large corporate-initial and
annual disclosure (SEBI
Circular
HO/DDHS/CIR/P/2018/144
dated 26 November 2018)
The due date for filing the yearly large corporate-initial disclosure has been
extended from 30 April 2020 to 15 May 2020.
The due date for filing the yearly large corporate-annual disclosure has been
extended from 15 May 2020 to 30 June 2020.
4.1.2 Enforcement of circular on SoP for imposition of fines and other enforcement actions
By its circular of 22 January 2020, SEBI issued the standard operating procedure on imposition of
fines and other enforcement actions for non-compliances with provisions of the LODR. The effective
date of operation of this circular has been extended and it will not apply for compliance periods ending
on or after 30 June 2020 (as opposed to 31 March 2020).
4.2 Relaxations under the Takeover Regulations
As per regulations 30(1) and 30(2) of the Takeover Regulations, every person who (together with persons
acting in concert) holds 25% or more of shares or voting rights in a target company and the promoter of every
company (together with persons acting in concert) are required to disclose their aggregate shareholding and
voting rights held in a listed company as of 31 March of each year. In addition, as per regulation 31(4) of the
Takeover Regulations, the promoter of every company (together with persons acting in concert) is required
to declare that on a yearly basis that he has not made any encumbrance on the shares held by him, directly
or indirectly, other than those already disclosed during the financial year. The due date for making this
disclosures/ declaration in relation to the financial year ending 31 March 2020 has been extended to 1 June
2020.
4.3 Relaxation for listing of NCDs/NCRPS/CPs
As per the relevant SEBI circulars, companies proposing to a make public issue of NCDs, NCRPs or CPs
are required to submit their audited financials which are not older than 6 months from the date of issuance.
By its notification of 23 March 2020, SEBI has permitted companies proposing to list their NCDs/ NCRPs/
CPs on or before 31 March 2020 to extend the date of issuance to 31 May 2020. These companies have
also been permitted to submit audited financial statements as on 30 September 2019, although the
requirement is that the audited financial statements must not be older than 6 months from the date of
issuance.
4.4 Relaxations for REITs and InvITs
By its notification of 23 March 2020, SEBI has extended the due dates for all regulatory filings and
compliances for REITs and InvITs for the period ending 31 March 2020 by one month over and above the
timelines prescribed under the REIT Regulations and the InvIT Regulations and the circulars issued
thereunder.
4.5 Relaxations for Mutual Funds, AIFs, VCFs and AMCs
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4.5.1 Mutual Funds – By its notification of 23 March 2020, SEBI has granted the following relaxations in
respect of compliances under the MF Regulations and the circulars issued thereunder:
(i) half yearly unaudited financial statements – the due date for filing the half yearly unaudited
financial results (Regulation 59) has been extended from 30 April 2020 to 31 May 2020;
(ii) commission paid to distributors – the due date for disclosure of the commissions paid to
distributors (Point 2(a) of Circular No. SEBI/HO/IMD/DF2/CIR/P/2016/42 dated 18 March 2016)
has been extended from 10 April 2020 to 10 May 2020; and
(iii) investor complaints – the due date for disclosure of the investor complaints with respect to
mutual funds (Point 4(b) of Circular No. Cir/IMD/DF/2/2010 dated 13 May 2010) has been
extended from 31 May 2020 to 30 June 2020.
(iv) new schemes – All mutual fund schemes where the observation letter was issued by SEBI and
are yet to be launched shall have a validity period of one year from the date of the SEBI letter
and all new mutual fund schemes where the final observation letter will be issued by SEBI shall
have a validity period of one year from the date of the SEBI letter.
4.5.2 Relaxations for AIFs and VCFs – By its notification of 30 March 2020, SEBI has extended the due
dates for all regulatory filings and compliances for AIFs and VCFs for the period ending 31 March 2020
and 30 April 2020 by two months over and above the timelines prescribed under the AIF Regulations
and the circulars issued thereunder.
4.5.3 Implementation of the Stewardship Code – By its circular of 24 December 2019, SEBI had introduced
the Stewardship Code for mutual funds and AIFs relating to stewardship responsibilities of monitoring
and actively engaging with investee companies on various matters including performance
(operational, financial, etc.), strategy, corporate governance (including board structure,
remuneration, etc.), material environmental, social, and governance opportunities or risks, capital
structure, etc. SEBI has extended the implementation of the Stewardship Code and it will now come
into effect from 1 July 2020 (as opposed to 1 April 2020).
4.5.4 Relaxation for AMCs – Additionally, in light of difficulties expressed by AMCs, the access control
presently exercised in the AMCs’ dealing rooms, including call recording of deals, has been temporarily
relaxed subject to checks and balances including electronic confirmation by way of email or other
system having audit trail in place.
4.6 Relaxations for FPIs, portfolio managers and CRAs
4.6.1 FPIs – As per the operational guidelines issued under the FPI Regulations, entities applying for
registration as FPIs are required to submit original KYC documents or attested copies where originals
cannot be submitted. By its notification of 30 March 2020, SEBI has permitted custodians and
designated depository participants to process FPI registration/ continuation requests (or KYC review
and any other material change) on the basis of scanned copies of KYC documents instead of originals,
provided that these documents are received from e-mail addresses of their global custodians/ existing
clients where these details are already captured in records; or e-mail addresses of new clients received
from domains which are duly encrypted with transport–layer security or similar encryption or the
documents are password protected. These relaxations will remain applicable until 30 June 2020, and
originals of all documents submitted during this period must be provided within 30 days following the
expiry of the relaxation period i.e. by 30 July 2020.
4.6.2 Portfolio Managers – By its notification of 30 March 2020, SEBI has provided an extension of two
months in respect of: (i) the monthly reporting to SEBI by portfolio managers for the periods ending 31
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March 2020 and 30 April 2020; and (ii) the implementation of the guidelines for portfolio managers
issued by SEBI by its circular dated 13 February 2020.
4.6.3 CRAs – By its notification of 30 March 2020, SEBI has permitting CRAs to not consider non-payment
of principal/ interest or any rescheduling of payment of debt obligation by issuer companies as a default
until the period of moratorium granted by the RBI i.e. 31 May 2020 (see paragraph 1.3.4 and paragraph
5 for details). In addition, the timelines/ due dates have been extended for rating action/ issue of press
releases and the annual and semi-annual disclosures required to be made by CRAs under the SEBI
(Credit Rating Agencies) Regulations, 1999.
5 Relaxations granted by the RBI
5.1 By its notification of 27 March 2020, the RBI has provided the following relaxations to borrowers and Lending
Institutions:
5.1.1 Lending Institutions have been permitted by the RBI to declare moratorium on payment of instalments
in relation to term loans which become due between 1 March 2020 and 31 May 2020. Instalment for
this purpose includes (i) principal and/or interest components; (ii) bullet repayments; (iii) equated
monthly instalments; and (iv) credit card dues. If a Lending Institution declares such a moratorium for
any term loan, the repayment schedule and the residual tenor of such loan will also be moved by 3
months to take the moratorium into account. However, interest will continue to accrue on the
outstanding amount during the moratorium period. Please note that the Indian Banking Association
has issued FAQs (Frequently Asked Questions) published on 1 April 2020 that this facility will be made
available to all borrowers across the board whose accounts are standard asset on 1 March 2020.
Further, to avoid unnecessary paperwork the facility has been extended across the board to all the
borrowers by extending repayment of term loan instalments (includes interest) by 90 days. It remains
to be seen if all banks will take the same approach, especially in relation to corporate borrowers.
5.1.2 Lending Institutions can also grant a moratorium on interest on working capital facilities availed of in
the form of cash credit or overdraft falling due between 1 March 2020 and 31 May 2020. Such interest
will become payable immediately after the completion of the moratorium period.
5.1.3 In respect of borrowers who have availed of working capital facilities in the form of cash credit or
overdraft and who are facing stress on their borrower account due to COVD-19, a Lending Institution
can recalculate their drawing limit by reducing the margins and/or by reassessing the working capital
cycle until 31 May 2020. Before providing this relaxation, the Lending Institution will have to satisfy
itself that such recalculation is required due to economic effects of COVD-19. The RBI has also
provided for subsequent supervisory review of such recalculated borrowing accounts to verify their
justifiability though it has not provided a process or timeline for this.
5.2 The RBI has also clarified that any relief granted or adjustment made pursuant to paragraph 5.1 above will
not lead to downgrade of asset classification of such borrower’s account or qualify as defaults for reporting
to credit information companies. However, Lending Institutions are required to formulate a board approved
policy for providing these reliefs which is be published in public domain. The RBI has also provided certain
procedural requirements which need to be complied with.
5.3 Realisation of export proceeds – The Export Regulations require that the full export value of goods, software
or services exported from India must be realised within 9 months from the date of export. Following an
amendment to the Export Regulations and by its notification of 1 April 2020, the RBI has extended the period
of realisation of export proceeds from 9 months to 15 months in respect of all exports made up to 31 July
2020.
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6 Relaxations granted by IRDAI
6.1 Submission of returns – The timeline for submission of monthly and quarterly returns for the month of
March 2020 by insurers and insurance intermediaries under the relevant regulations has been
extended by a period of 15 days.
6.2 Submission of final re-insurance programme – As per the applicable regulations, insurers are required
to file their respective board approved final re-insurance programme for the financial year 2020-21 by
30 April 2020 along with a synopsis of catastrophe modelling report. IRDAI has extended the due date
for this filing to 31 May 2020.
6.3 Insurance premiums – IRDAI has granted the following relaxations in relation to payment/ charging of
premiums in respect of insurance products:
6.3.1 insurers have been asked to grant a grace period of up to 30 days for payment of renewal
insurance premiums in respect of life insurance policies, if desired by the policyholders;
6.3.2 insurers may condone a delay of up to 30 days in renewal of health insurance policies without
considering such delay as a break in the policy; and
6.3.3 insurers are required to continue charging the current premium rates being charged in respect
of motor third party liability insurance cover from 1 April 2020 until further orders.
7 CONCLUSION
The above relaxations are initial steps to ease the immediate difficulties caused by the coronavirus epidemic
and consequent lockdown and more steps are anticipated, particularly as more becomes known as to the
duration of the lockdown and its negative economic consequences.
2 April 2020
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Contacts
For further information please contact:
This publication only highlights key issues and is not intended to be comprehensive. The contents of this publication do not constitute any opinion or determination on,
or certification in respect of, the application of Indian law by Talwar Thakore & Associates (“TT&A”). No part of this publication should be considered an advertisement
or solicitation of TT&A’s professional services. This communication is confidential and may be privileged or otherwise protected by work product immunity.
Kunal Thakore
Partner, Corporate
+91 22 6613 6961
Feroz Dubash
Partner, Corporate
+91 22 6613 6932
Anurag Shrivastav
Managing Associate
+91 22 6613 6942
Deepa Christopher
Counsel
+91 22 6613 6943
Sonali Mahapatra
Partner, Banking &
Finance
+91 22 6613 6988
Nidhi Rani
Counsel
+91 22 6613 6947