Integrated Filing-Governance (XBRL) – Explanation, Requirements, and Filing Process

The Integrated Filing-Governance (XBRL) format introduced by SEBI and the NSE aims to simplify the compliance process for listed companies by consolidating multiple reports into a single submission. The primary goal is to ensure that listed entities can file their governance and investor grievance data more efficiently and in a standardized format.

This new filing format is mandatory from the quarter ending March 31, 2025 onwards, and companies are required to submit the Integrated Filing-Governance (XBRL form) within 30 days from the end of the quarter.

Reference to the SEBI Circular No. SEBI/HO/CFD/CFD-PoD-2/CIR/P/2024/185 dated December 31, 2024 ( SEBI Circular ) read with various Exchange Circulars bearing Circular Ref No: NSE/CML/2025/02 dated January 02, 2025, Circular Ref No: NSE/CML/2025/03 dated January 13, 2025 and Circular Ref. No.: NSE/CML/2025/07 dated February 28, 2025 regarding implementation of recommendations of the Expert Committee for facilitating ease of doing business for listed entities in relation to the filing of Integrated Filing-Governance.

Where to Seek Help and Clarifications:

For any queries related to these updates or issues faced while filing the new Integrated Filing-Governance (XBRL form), listed entities can contact the following:

• NEAPS (NSE Electronic Application Processing System): NEAPS provides a platform where entities can file their compliance reports. The Help Desk section on NEAPS offers support for any issues.
• Email Contacts:
  • [email protected]
  • [email protected]

These email contacts can be used to reach out for clarification or technical support regarding the new filing process.

Key Elements of Integrated Filing-Governance (XBRL):

1. Consolidation of Multiple Reports: Previously, listed companies had to file separate XBRL reports for corporate governance and investor grievances. Now, these are integrated into one single XBRL form for ease of filing.
2. Compliance Data: The form contains details related to:
   • Corporate Governance: Information related to the composition of the board, committees, policies, and other governance aspects.
   • Investor Grievances: Data about investor complaints, resolution status, and any actions taken.

Steps to File Integrated Filing-Governance (XBRL):

1. Review the Filing Timeline:

• From the quarter ending March 31, 2025, the XBRL submission must be completed within 30 days from the quarter-end. For example, if the quarter ends on March 31, 2025, the filing should be submitted by April 30, 2025.

2. Collect the Required Information:

Ensure that all the required data related to corporate governance and investor grievances is accurate and up-to-date. This includes:

• Board Composition: Number of directors, independent directors, committees, and policies related to board functioning.
• Investor Grievances: Number of complaints received, resolved, pending, and actions taken.
• Any additional governance-related information required by SEBI and NSE guidelines.

3. Prepare the XBRL Data:

• XBRL Conversion: Your company’s compliance data must be converted into XBRL format, which follows the specific schema set by SEBI and NSE. This involves:
  • Using XBRL software or services to convert the data into the structured XBRL format.
  • The XBRL format allows for easy uploading and analysis of large amounts of data in a standardized way.

4. File the XBRL Report on NEAPS Platform:

The NSE Electronic Application Processing System (NEAPS) is where listed entities will file their Integrated Filing-Governance (XBRL) reports. Here’s how you can do it:

• Log in to the NEAPS platform using your company’s credentials.
• Select the appropriate section for filing XBRL Reports under Corporate Governance and Investor Grievances.
• Upload the XBRL form and verify all the data before submission.
• Ensure that all mandatory fields are filled correctly.

5. Validate the Data Before Submission:

• Check for Errors: Make sure that all fields in the XBRL form are filled out correctly and match your internal records. Any discrepancies can lead to penalties or rejections.
• Use Validation Tools: Most XBRL software comes with validation tools that can check the data’s accuracy before submission. Ensure the data is error-free.

6. Submit the Filing:

Once all the details are verified and the form is complete, submit the Integrated Filing-Governance (XBRL) form through NEAPS.

7. Obtain Acknowledgement and Confirmation:

After submission, NEAPS will provide an acknowledgment receipt confirming the submission. Keep this receipt for your records, as proof of compliance with the SEBI and NSE requirements.

Example of What to Include in the Integrated Filing-Governance (XBRL):

While the exact structure of the XBRL form is defined by SEBI and NSE, here’s an illustrative template of the type of data that would typically be included. Please note that this is just an example, and the final template will depend on the specific requirements set by SEBI and NSE:

Corporate Governance Section:

Investor Grievances Section:

Important Points to Note:

• No Separate Corporate Governance & Investor Grievance XBRL: From the quarter ending March 31, 2025, onwards, the previously separate XBRL filings for corporate governance and investor grievance reports are not required. Everything will be filed in the new Integrated Filing-Governance (XBRL form).
• Accuracy: The data you file must be accurate and align with your internal records. Any discrepancies or inaccuracies could lead to penalties or regulatory issues.
• File Timeliness: Ensure that your filing is completed within 30 days of the quarter-end to avoid any late fees or compliance issues. For instance, for the quarter ending March 31, 2025, the filing is due by April 30, 2025.

Conclusion:

The Integrated Filing-Governance (XBRL) format simplifies compliance for listed companies by consolidating multiple governance and grievance-related filings into a single submission. By ensuring that you gather accurate data, use the correct XBRL software for conversion, and submit the form on time, your company will meet SEBI and NSE’s updated requirements efficiently.

For further clarification or if you need help with filing the XBRL form, you can reach out to NSE’s contact points provided in the circular or consult with your compliance team.