Who Can Use SEBI's Special Window? Eligibility for Transfer Deeds Signed Before April 2019

The special window SEBI opened on 5 February 2026 is narrower than its name suggests. It isn't a general amnesty for old paper shares. It helps one kind of person: someone who bought physical shares from another shareholder before 1 April 2019, signed a transfer deed, and never got the shares registered in their name.

Why April 2019 matters

From 1 April 2019, listed companies stopped registering transfers of shares held in physical form. A buyer holding a signed deed and the seller's certificates had no way left to complete the transfer. The window, open until 4 February 2027, lets those buyers finish it.

The two conditions

SEBI's circular of 30 January 2026 sets a short test. Both must be true:

• The transfer deed was executed before 1 April 2019: the date the seller and buyer signed it, not the date it reached the company
• You have the original share certificate: a photocopy, dividend warrant or folio statement is not a substitute

Whether you lodged the deed with the company before makes no difference. A deed that was never sent counts as a fresh lodgement; one that was sent and rejected or returned can be lodged again.

SEBI's matrix, in plain words

• Deed before April 2019, never lodged, original certificate in hand: eligible
• Deed before April 2019, lodged and rejected or returned, original certificate in hand: eligible
• Deed before April 2019, lodged earlier, original certificate not available: not eligible
• Deed before April 2019, never lodged, original certificate not available: not eligible

Which transfer deeds count

The undertaking SEBI prescribes for the window refers to two forms: the older Form 7B instrument of transfer from the Companies Act, 1956, and Form SH-4 under the Companies Act, 2013. Deeds signed before the 2013 Act's share capital rules came into force in 2014 are usually on Form 7B.

Who is excluded

• Disputes: if the seller, or the seller's family, contests the sale, the window does not apply. The circular leaves those cases to a court or the NCLT.
• Shares already with IEPF: shares the company transferred to the Investor Education and Protection Fund, usually because dividends went unclaimed for seven years, are outside the window. Here is how to check.
• No original certificate: see what the window can and can't do for a lost certificate.

One more case is worth knowing. If the buyer named on the deed has since died, the family doesn't apply under the window in the buyer's name. The legal heirs claim the shares through the transmission procedure, with the documents it requires.

You will need a demat account

Shares transferred through the window are credited only in demat form, and they are locked in for a year. Open a demat account in your own name before applying. The registrar needs its Client Master List, not more than two months old and attested by your depository participant.

A five-question self-check

• Is the date on the transfer deed earlier than 1 April 2019?
• Do you hold the original certificates the deed refers to, with matching folio and certificate numbers?
• Are the shares still with the company, and not transferred to IEPF?
• Is everyone, including the seller's family, accepting that the sale happened?
• Do you have, or can you open, a demat account in the name on your PAN?

Five yeses put you in the group the window was written for. The document checklist lists what to send.