The Securities Markets Code, 2025 would replace the three laws that run India’s stock and bond markets: the Securities Contracts (Regulation) Act, 1956, the Securities and Exchange Board of India (SEBI) Act, 1992 and the Depositories Act, 1996. Finance Minister Nirmala Sitharaman introduced it in the Lok Sabha on 18 December 2025 and it went to the Standing Committee on Finance, chaired by Bhartruhari Mahtab, which reported on 23 July 2026. The Code was not taken up in the Monsoon Session that ended on 13 August, so it remains pending. This piece sets out what the committee wants changed, and then checks the changes against how long SEBI’s investigations, appeals and recoveries actually take.

What the committee wants changed

The committee broadly backed a single code and a stronger SEBI, but asked for limits on how SEBI uses its powers. Its main recommendations, as summarised by PRS Legislative Research, are below.

Bill and committee positions from PRS Legislative Research’s bill summary, legislative brief and report summary, read through search-engine text; the report itself was not opened.

Some details do not fit a table. The Code also bars SEBI from starting an inspection or investigation more than eight years after a breach. The committee chair told ANI the new investigation limit would be 360 days rather than a calendar year. For market infrastructure institutions (MIIs: stock exchanges, clearing corporations and depositories), the committee also wants public consultation on bye-law changes, a maximum period for any government takeover, and the Code to spell out which functions SEBI may hand to them.

Two of these changes restore what the 1992 law already allows. The SEBI Act lets “any person aggrieved” by a SEBI order appeal to SAT; the Code’s list of appealable orders would have narrowed that, and the committee wants the wider wording back. And because market abuse is a jailable offence, letting SEBI redefine it by regulation would let a regulator decide what counts as a crime, which is why the committee wants that power deleted.

Investigations: 180 days against a growing pile

SEBI took up 400 investigations in 2024-25, the most in decades, and completed 301; in 2023-24 it took up 342 and completed 197. The completed count includes cases opened in earlier years, so the two bars are not the same cases. What the gap does show is the direction of the backlog. Between 2013-14 and 2023-24 SEBI took up 1,667 cases and completed 1,603. Taking out 2023-24, the ten years to 2022-23 saw 1,325 taken up and 1,406 completed, so the stock of open cases fell by about 81. In the next two years it rose by 145 and then 99, a net 244 more open cases.

Against that, a 180-day deadline was never going to hold. PRS notes that most investigations take one to one-and-a-half years, and the Code allowed unlimited extensions, which would have made the deadline a formality. The committee’s one year is closer to what happens, but only if the number of investigators keeps pace with a caseload that has more than doubled since 2022-23. Insider trading is now the largest category: 287 of the 400 cases in 2024-25, against 106 for market manipulation and price rigging.

Appeals: fewer filed, most dismissed

New appeals against SEBI to the Securities Appellate Tribunal fell from 821 in 2023-24 to 533 in 2024-25, according to SEBI’s annual report. Of the 422 appeals disposed of that year, 308 (73%) were dismissed, 42 upheld with changes, 28 withdrawn, 23 allowed and 21 sent back to SEBI. SAT itself received a record 1,192 appeals of all kinds in 2022-23, and has spent long stretches with a single bench and sometimes without a quorum.

Opening every SEBI order to appeal, as the committee wants, will add cases. The dismissal rate suggests most appeals do not overturn SEBI, but interim orders such as trading bans and freezes can do lasting harm before a final order arrives, which is the committee’s reason for wanting them appealable. The cost is more work for a tribunal that has struggled to stay fully staffed.

Settlements and recoveries

Many cases end in settlement rather than an order. Applications rose from 434 in 2023-24 to 703 in 2024-25, when SEBI settled 284 and collected about Rs 799 crore. In 2025-26, according to secondary summaries of a SEBI consultation paper, applications fell to 439 and 170 were settled.

* 2025-26 figures are from secondary summaries of SEBI’s August 2026 consultation paper on settlement regulations and could not be checked against the annual report; the charges figure in particular looks low and should be treated with caution. A dash means the figure was not found.

Collecting money is harder than ordering it paid. A Business Standard analysis of SEBI’s annual reports found that recovery notices worth about Rs 1.06 lakh crore were issued from 2013-14 to 2023-24, and about Rs 1,768 crore was recovered, roughly 1.7%. SEBI classes dues as “difficult to recover” once every recovery route has been tried; that figure keeps rising.

Most of it is not ordinary market fraud. Over Rs 61,200 crore of the March 2025 total sits in cases before court-appointed committees, chiefly the PACL and Sahara collective-investment schemes. The Code’s faster investigation deadlines and the committee’s appeal rights do not touch this pile; it depends on courts and asset sales.

What would fix this

• SEBI should publish, each year, its stock of open investigations at the start and end of the year and their age, not only cases taken up and completed, so the effect of any statutory deadline can be checked.
• If the Code sets a one-year deadline, extensions should be capped and each one recorded with reasons in the annual report, so the limit cannot become routine.
• The Code should require SAT to sit with its full statutory strength and report its pending appeals and median disposal time each year, since wider appeal rights will add to its load.
• “Difficult to recover” dues should be reported in two parts: cases before court-appointed committees (PACL, Sahara) and everything else, so recovery from ordinary enforcement can be judged on its own.

These are proposals from this blog, not recommendations any agency has adopted.

What this piece could not establish

The Code, the committee report and SEBI’s annual reports were read only through PRS summaries and news coverage indexed by search engines; none of the documents were opened. The committee’s investigation deadline is reported as “one year” by PRS and “360 days” by the chair in an interview. SEBI’s 2025-26 annual report, released in August 2026, was located but its enforcement chapter could not be read, so no 2025-26 investigation counts are given. The number of investigations completed in 2021-22 and the number of appeals pending before SAT at the end of 2024-25 or 2025-26 could not be found from a reliable source; one secondary article’s claim of over 2,800 pending appeals is not used. Whether the government will accept the committee’s changes, and when the Code returns to Parliament, is not known. This is not legal advice.

Sources and caveats

About this article: Researched, written and edited by Umashankar Triplicane Dwarakanathan, with AI research assistance; every figure is meant to trace to the primary source cited. See the Editorial Policy for how sourcing, AI use and corrections work.