SEBI sets the ISIN cap for privately placed debt at seventeen maturing in a financial year, with extra ISINs above ₹15,000 crore: Circular HO/17/11/24(8)2026-DDHS-POD1/I/23125/2026
SEBI has replaced paras 1.1 to 1.3 of the ISIN provisions of its NCS Master Circular to increase the maximum number of ISINs maturing in a financial year for debt securities issued on private placement basis. An issuer is now allowed seventeen ISINs maturing in any financial year: twelve for plain vanilla debt and five for structured, market linked, floating rate, zero coupon and Tier II instruments, plus six more for section 54EC capital gains bonds. The change took effect immediately on 7 October 2026.
Key facts
- In force
- Immediate effect from 7 October 2026
- Who it affects
- Issuers of listed debt securities on private placement basis, authorised issuers of section 54EC bonds, stock exchanges, depositories
- What it is
- Rule change
- Section
- SEBI
- Published
- 7 October 2026
In 30 seconds
- The circular is dated 7 October 2026 and amends Chapter VIII (specifications related to ISIN for debt securities) of the NCS Master Circular dated 15 October 2025.
- A maximum of seventeen ISINs maturing in any financial year is allowed per issuer, with a further six ISINs for section 54EC capital gains tax debt securities issued by authorised issuers.
- Twelve of the seventeen are for plain vanilla debt securities, secured and unsecured together.
- Once the outstanding amount across the twelve ISINs maturing in a financial year reaches ₹15,000 crore, one additional ISIN may be permitted for each additional issuance of ₹3,000 crore.
- Five ISINs are for structured debt, market linked debt, Floating Rate Bonds, Zero Coupon Bonds and Debt Capital instruments (Tier II bonds); existing FRB, ZCB and Tier II ISINs are grandfathered.
- ISINs of Government of India serviced / Extra Budgetary Resources bonds and of ESG debt securities are excluded when calculating the limits.
हिंदी में सार
SEBI ने 7 अक्टूबर 2026 के सर्कुलर से private placement पर जारी debt securities के लिए एक वित्त वर्ष में परिपक्व होने वाले ISIN की अधिकतम संख्या सत्रह तय की है — बारह plain vanilla debt के लिए और पाँच structured, market linked, floating rate, zero coupon और Tier II बॉन्ड के लिए। धारा 54EC के capital gains बॉन्ड के लिए छह ISIN अलग से मिलेंगे। बारह ISIN में बकाया राशि ₹15,000 करोड़ पहुँचने पर हर अतिरिक्त ₹3,000 करोड़ के निर्गम पर एक और ISIN मिल सकता है। GoI serviced/EBR बॉन्ड और ESG debt securities गिनती से बाहर हैं; प्रावधान तुरंत प्रभाव से लागू हैं।
What SEBI has decided
Chapter VIII of SEBI’s Master Circular for Issue and Listing of Non-Convertible Securities, Securitised Debt Instruments, Security Receipts, Municipal Debt Securities and Commercial Paper dated 15 October 2025 (the NCS Master Circular) deals with specifications related to ISIN for debt securities.
By a circular dated 7 October 2026, SEBI has decided to increase the maximum number of ISINs maturing in a financial year for debt securities issued on private placement basis. It says the decision is based on feedback from market participants and is meant to enhance ease of fund raising and Asset Liability Management by issuers. Paras 1.1, 1.2 and 1.3 are replaced. The circular sets out the new limits; it does not restate the limits that applied earlier.
The new limits
| Category | Maximum ISINs maturing in a financial year |
|---|---|
| Overall limit for an issuer of debt securities | Seventeen |
| Plain vanilla debt securities (secured and unsecured, within the same limit) | Twelve, out of the seventeen |
| Structured debt securities, market linked debt securities, Floating Rate Bonds (FRBs), Zero Coupon Bonds (ZCBs) and Debt Capital instruments (Tier II bonds) | Five, out of the seventeen |
| Capital gains tax debt securities issued by authorised issuers under section 54EC of the Income Tax Act, 1961 on private placement basis | A further six, in addition to the seventeen |
| An issuer that issues only structured / market linked debt securities / FRBs / ZCBs / Debt Capital instruments (Tier II bonds) | Twelve |
Additional ISINs for large outstanding amounts
If the total outstanding amount across the twelve plain vanilla ISINs maturing in a given financial year reaches ₹15,000 crore, then for each additional issuance of ₹3,000 crore, one additional ISIN may be permitted to mature in the same financial year. The circular gives this illustration:
| Outstanding amount maturing in a financial year (₹ crore) | Applicable ISIN limit |
|---|---|
| 1 to 15,000 | 12 |
| 15,001 to 18,000 | 13 |
| 18,001 to 21,000 | 14 |
| For every incremental 3,000 | +1 |
Grandfathering of existing FRB, ZCB and Tier II ISINs
Existing ISINs pertaining to FRBs, ZCBs and Debt Capital instruments (Tier II bonds) that were issued before the date of the circular, are outstanding and are scheduled to mature in any subsequent financial year are grandfathered, to avoid any unintended breach of the ISIN cap.
There is a restriction attached. If the number of such outstanding legacy ISINs maturing in a subsequent financial year already equals or exceeds five, the issuer cannot issue any further new ISIN in this category for that financial year, including for structured and market linked debt securities, until the total number of maturing ISINs in the category falls below five.
Instruments left out of the count
ISINs pertaining to the following are excluded while calculating the applicable ISIN limits for an issuer:
- Government of India (GoI) serviced / Extra Budgetary Resources (EBR) bonds;
- Environment, Social and Governance (ESG) Debt Securities issued in terms of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021.
Effective date
The provisions come into force with immediate effect. All other provisions of Chapter VIII of the NCS Master Circular remain unchanged. Stock exchanges and depositories are advised to amend their bye-laws, rules and regulations as necessary, carry out system changes, disseminate the circular, report the status of implementation to SEBI and monitor compliance by issuer companies.
What issuers should do
Issuers that raise debt by private placement should recount their ISINs maturing in each financial year under the two categories, leaving out GoI serviced / EBR bonds and ESG debt securities. Issuers with legacy FRB, ZCB or Tier II ISINs should check whether five or more of them mature in any one financial year, because no new ISIN in that category can then be issued for that year.
Questions and answers
How many ISINs can an issuer of privately placed debt now have maturing in a financial year?
A maximum of seventeen ISINs maturing in any financial year. In addition, a further six ISINs are available for capital gains tax debt securities issued by authorised issuers under section 54EC of the Income Tax Act, 1961 on private placement basis.
How are the seventeen ISINs divided?
A maximum of twelve are for plain vanilla debt securities, within which the issuer can issue both secured and unsecured debt securities. A maximum of five are for structured debt securities, market linked debt securities, Floating Rate Bonds, Zero Coupon Bonds and Debt Capital instruments (Tier II bonds).
When can an issuer go beyond twelve plain vanilla ISINs?
When the total outstanding amount across the twelve ISINs maturing in a given financial year reaches ₹15,000 crore. For each additional issuance of ₹3,000 crore, one additional ISIN may be permitted to mature in the same financial year. In the circular’s illustration the limit is 13 for ₹15,001 to 18,000 crore and 14 for ₹18,001 to 21,000 crore.
What happens to existing Floating Rate Bond, Zero Coupon Bond and Tier II ISINs?
Those issued before the date of the circular that are outstanding and mature in a subsequent financial year are grandfathered. But if five or more such legacy ISINs already mature in a financial year, the issuer cannot issue any new ISIN in that category for that year until the number falls below five.
Which ISINs are not counted towards the limit?
ISINs of Government of India serviced / Extra Budgetary Resources bonds, and of ESG Debt Securities issued in terms of the SEBI (Issue and Listing of Non-Convertible Securities) Regulations, 2021.
Published 7 October 2026. Updated 13 October 2026. This report is for general information and is not professional advice. Read the source document before acting on it.