Share Transfer Rejected Years Ago? Relodging It Under SEBI's 2026 Window

Most old share transfers that failed did not fail over anything serious. The registrar sent the papers back with a short objection memo: the seller's signature didn't match the specimen on record, the deed was incomplete, a stamp was missing. The buyer meant to sort it out, and then April 2019 arrived and companies stopped registering physical transfers at all.

SEBI's circular of 30 January 2026 covers these cases by name. The special window is open to transfer requests that were submitted earlier and "rejected/returned/not attended to" because of a deficiency.

How this differs from the 2025 window

SEBI's earlier window, open from 7 July 2025 to 6 January 2026, was for re-lodging transfer deeds. The 2026 window, open until 4 February 2027, covers rejected deeds and also deeds that were never lodged at all. If a request you made in the 2025 window didn't go through, ask the registrar whether it can be lodged again in this one with the deficiency fixed.

Start with the old objection memo

If you still have the registrar's letter returning the transfer, it tells you what was wrong. Fix that first. Here is how the usual objections are handled under the window:

• Seller's signature differs from the company's records: the circular applies the signature procedure in Schedule VII of SEBI's Listing Regulations. The registrar writes to the seller; if that letter can't be delivered or the seller doesn't cooperate, the company publishes a notice and waits 30 days for objections.
• Seller's signature missing: handled under the same procedure as a mismatch
• Your PAN name differs from the name on the deed: send an officially valid document or a gazette notification that explains the difference
• Seller's PAN, ID or address proof unavailable: the circular requires them to be verified. Where they aren't available, the newspaper notice route applies, for which the company may charge a minimal fee.

The notice procedure is explained step by step in how registrars process special window requests.

Documents your first request didn't have

Even where the original problem was minor, a relodged request needs documents that did not exist when you first sent it:

• A Client Master List for your demat account, not more than two months old and attested by your depository participant
• Your KYC documents, on the ISR forms
• An undertaking-cum-indemnity bond in SEBI's format, on non-judicial stamp paper and notarised

You still need the original share certificates and the original transfer deed. If you are not sure whether the company kept anything when it returned your request, write to the registrar and ask, quoting the folio and certificate numbers.

Is a deed from the 1990s too old?

This is the question we hear most. The circular's only condition on the deed's date is that it was executed before 1 April 2019. The window was opened for exactly these deeds.

When relodging won't work

• The seller or their family now disputes the sale: disputes are excluded and left to the courts
• The shares have gone to IEPF: the window doesn't apply to shares already transferred there. Get advice on whether any other route is open to you as buyer.
• The original certificates are lost: see the lost-certificate problem

If none of those apply, work through the document checklist and relodge well before 4 February 2027. A request with a gap in it can take weeks to come back to you, and the window will not wait.