The Bar Council of India does not permit advertisement or solicitation by advocates in any form or manner. By accessing this website, www.khaitanco.com, you acknowledge and confirm that you are seeking information relating to Khaitan & Co of your own accord and that there has been no form of solicitation, advertisement or inducement by Khaitan & Co or its members. The content of this website is for informational purposes only and should not be interpreted as soliciting or advertisement. No material/information provided on this website should be construed as legal advice. Khaitan & Co shall not be liable for consequences of any action taken by relying on the material/information provided on this website. The contents of this website are the intellectual property of Khaitan & Co.

Please accept the above


See all results for ""

Enhancement of UPI limits for public issue of debt securities



The Securities and Exchange Board of India (SEBI) vide circular number SEBI/HO/DDHS/P/CIR/2022/0028 dated 8 March 2022 (Revision Circular), has amended the Operational Circular bearing number SEBI/HO/DDHS/P/CIR/2021/613 dated 10 August 2021, in respect of procedures pertaining to issue and listing of non-convertible securities, securitised debt instruments, security receipts, municipal debt securities and commercial paper (Operational Circular).


The National Payments Corporation of India (NPCI) had issued a circular bearing reference number NPCI/UPI/OC No. 127/ 2021-22 dated 9 December 2021 (Circular), whereby, it had enhanced the per transaction limit in unified payments interface mechanism (UPI) from INR 2 lakh to INR 5 lakh for UPI based Application Supported by Blocked Amount (ASBA) with respect to initial public offers of debt securities.


The Operational Circular provided for investors to apply in public issues of debt securities with the facility to block funds through UPI mechanism for application value upto INR 2 lakh. The Revision Circular brings UPI mechanisms under the Operational Circular in line with the Circular, which shall be operative for public issues of debt securities which open on or after 1 May 2022.

Key Amendments introduced by the Revision Circular

The new amendments in Chapter (I) and (II) of the Operational Circular prescribe that the value in respect of payments made under UPI stands increased to INR 5 lakh from the previous value of INR 2 lakh. Accordingly, an investor may submit the bid-cum-application form with a self-certified syndicate bank or a recognised intermediaries and use their bank account linked UPI ID for the purpose of blocking of funds, if the application value is less than INR 5 lakh. Further, stock exchanges have been mandated to provide a platform for making applications through app based / web interface from investors with UPI mode for blocking the mode for application value upto INR 5 lakh.

Chapter II (Application Form and Abridged Prospectus) has been amended accordingly and prescribes that the overleaf of the application form shall include UPI mechanism for blocking funds would be available for application value upto INR 5 lakh.

Also, in order to remove any ambiguity, the definition of a ‘Sponsor Bank’ has been modified to mean,

“a banker to the issue registered with SEBI which is appointed by the issuer to act as a conduit between the stock exchanges and the NPCI in order to push the mandate collect requests and / or payment instructions of the investors into the UPI”,

whereas previously “investors” read as “retail investors” under this definition. This clarifies that UPI mechanisms are not exclusive to “retail investors” as the Operational Circular prescribed before.


The Revision Circular has been issued to ensure uniformity in payment mechanisms wide the market participants (for both debt and equity investments, and specifically to align with the Circular) and for ease of investment to investors. UPI mechanisms offer great flexibility and ease of operation to Investors and widening its scope could definitely be viewed as an investor friendly move by SEBI.

-         Manisha Shroff (Partner), Soumya Mohapatra (Partner), Sonakshi Faujdar (Associate) and Saranya Karanath (Associate)

For any queries please contact: editors@khaitanco.com ​​​​​​​

Manisha Shroff (partners) , Soumya Mohapatra (partners)

We have updated our Privacy Policy, which provides details of how we process your personal data and apply security measures. We will continue to communicate with you based on the information available with us. You may choose to unsubscribe from our communications at any time by clicking here.

For private circulation only

The contents of this email are for informational purposes only and for the reader’s personal non-commercial use. The views expressed are not the professional views of Khaitan & Co and do not constitute legal advice. The contents are intended, but not guaranteed, to be correct, complete, or up to date. Khaitan & Co disclaims all liability to any person for any loss or damage caused by errors or omissions, whether arising from negligence, accident or any other cause.

© 2021 Khaitan & Co. All rights reserved.


One Forbes
3rd & 4th Floors, No. 1
Dr. V. B. Gandhi Marg
Fort, Mumbai 400 001


119/65, First Floor
Dr Radhakrishnan Salai
Chennai 600 004,


Max Towers
7th & 8th Floors
Sector 16B, Noida
Gautam Buddh Nagar
201 301 India


Ocean Financial Centre
#37-02 10 Collyer
37th Floor Quay
Raffles Place 049315,