Amendment diff · AMD-2026-CUSPA

Amendment Redline

On 2026-07-03 SEBI replaced the CUSA transfer regime for clients’ unpaid securities with a pledge-based CUSPA mechanism. Below is the agent-computed clause-level redline — every changed provision, the obligations it created or re-mapped, and the phased deadlines it set. 10 obligations re-mapped · 33 untouched.

Corpus lineage — unpaid securities3 instruments · sim-today 2026-07-12

superseded

MC-SB-2024Master Circular for Stock Brokers (prior edition)retired 2025-06-17 · consolidated into MC-SB-2025

superseded by

in force

MC-SB-2025Master Circular for Stock Brokersissued 2025-06-17 · 23 base obligations · ingested by RUN-041

amended by

active amendment

CIRC-CUSPA-2026Handling of Clients’ Unpaid Securities — pledge-based CUSPAissued 2026-07-03 · 10 diff blocks · para 46 only

caught by Watchtower →processed in RUN-047 →

10Diff blocks in para 463 modified · 7 added

10Obligations re-mapped6 gaps · 3 pending review · 1 at risk

33Obligations untouchedevidence bindings intact — no re-work

113Days to phase 12026-11-02 · paras 46.1–46.11

Replaces the CUSA account-transfer regime for clients' unpaid securities with a pledge-based CUSPA mechanism: dedicated pledgee account, auto-pledge on pay-out, client intimation, a hard five-trading-day payment window with day-six auto-release, a structured extension process, prohibition on transfer to banks/NBFCs, and daily reconciliation — with phased effectivity.

AMD-2026-CUSPA · diff computed by agent:diff in RUN-047 · verifier checks 5/5 ✓3 mappings awaiting compliance-officer approval →

Clause-level redline — para 46, side by side

Before · MC-SB-2025 — Master Circular for Stock Brokers · issued 2025-06-17After · CIRC-CUSPA-2026 — CUSPA amendment · issued 2026-07-03

··· Paras 4.1 – 31.5 · Registration & Client Dealings — unchanged9 obligations untouched · evidence intact

before · MC-SB-2025

Securities that have been received in pay-out against which clients have not made full payment shall be transferred by the trading member to a separate demat account titled 'client unpaid securities account' (CUSA).

after · CIRC-CUSPA-2026

Every trading member shall open a separate demat account designated as the 'Client Unpaid Securities Pledgee Account' (CUSPA), tagged as such with the depository, exclusively for taking a pledge of unpaid securities of clients.

before · MC-SB-2025

Unpaid securities lying in the client unpaid securities account shall either be transferred to the demat account of the respective client upon fulfilment of the client's funds obligation, or shall be disposed of in the market by the trading member within five trading days after the pay-out.

after · CIRC-CUSPA-2026

Securities received in pay-out against which the client has not made full payment shall be transferred to the respective client's demat account, followed by creation of an auto-pledge in favour of the trading member's CUSPA, without requiring any separate instruction or authorisation from the client.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

Upon creation of the pledge referred to above, the trading member shall intimate the client through email and SMS, specifying the securities pledged, the amount outstanding, and the date by which the pledge shall be invoked or released.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

The trading member shall frame a policy on handling of clients' unpaid securities, approved by its board, which shall in no case permit a payment window exceeding five trading days from the date of pay-out.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

Where the client fails to meet the funds obligation within five trading days from the pay-out, the trading member may invoke the pledge to the extent of the unpaid amount; where the pledge is not invoked, it shall be auto-released on the sixth trading day and the securities shall be free in the client's demat account.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

In exceptional circumstances, the trading member may request an extension of the invocation timeline from the stock exchange, in the manner specified, by six p.m. on the fifth trading day, for a period not exceeding one week at a time; such request may be repeated only where the exceptional circumstances persist.

before · MC-SB-2025

Securities kept in the client unpaid securities account shall not be used for any purpose other than as set out above, and under no circumstances shall such securities be pledged or transferred to any third party, including towards the trading member's own obligations.

after · CIRC-CUSPA-2026

Unpaid securities of clients shall not be transferred or pledged, in any circumstance, to any bank or non-banking financial company, including towards the trading member's own borrowings or funding arrangements.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

The trading member shall carry out, on each trading day, a reconciliation of the maximum value of securities eligible to be pledged to the CUSPA against the aggregate unpaid obligations of clients, and shall preserve the records of such reconciliation.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

Trading members shall ensure that their client agreements, terms and conditions, and policies are updated to reflect the pledge-based mechanism for unpaid securities set out in this circular, and shall disseminate the updated terms to all existing clients.

before · MC-SB-2025

No corresponding provision — inserted by the amendment.

after · CIRC-CUSPA-2026

Paragraphs 46.1 to 46.11 shall come into force three months from the date of issuance of operational guidelines by the stock exchanges, which shall be issued within thirty days of the date of this circular; paragraphs 46.12 to 46.14 shall come into force six months from the date of this circular.

··· Paras 52.1 – 103.2 · Margin through Cyber (CSCRF) — unchanged24 obligations untouched · evidence intact

Phased effectivity — CUSPA regimeper para 46.14 · OBL-SB-109 tracks this

today

Amendment issued

2026-07-03 · CIRC-CUSPA-2026

Exchange operational guidelines due

2026-08-02 · 30 days from issuance

Phase 1 in force — paras 46.1–46.11

2026-11-02 · 8 obligations · 113 days out

Phase 2 in force — paras 46.12–46.14

2027-01-03 · 2 obligations

10 obligations re-mapped — 6 gaps · 3 pending review · 1 at risk — and 33 untouched, their evidence bindings intact. Seven remediation tasks were opened from this run.

Review the delta →7 tasks queued →Replay RUN-047 →