SAST is the SEBI (Substantial Acquisition of Shares and Takeovers) Regulations, 2011. Most of the regulation governs open offers. The part that produces a steady stream of readable filings is Regulation 29, which forces anyone building a meaningful position in a listed company to say so.
What Regulation 29 requires
| Sub-regulation | Trigger | Who files |
|---|---|---|
| 29(1) | Acquisition taking the acquirer, together with persons acting in concert, to 5 percent or more of the shares of the target company | The acquirer |
| 29(2) | A change exceeding 2 percent of total shareholding or voting rights, for anyone already holding 5 percent or more, including a change that takes them below 5 percent | The holder |
Both disclosures go to every stock exchange where the shares are listed and to the target company at its registered office, within two working days of receipt of intimation of allotment, or of the acquisition or disposal. For a company listed on the Innovators Growth Platform, the 5 percent reference reads as 10 percent and the 2 percent reference as 5 percent.
Regulation 29(4) adds a wrinkle worth knowing. Shares taken by way of encumbrance are treated as an acquisition and shares given up on release of encumbrance as a disposal, so pledges can trigger Regulation 29 filings too. Scheduled commercial banks, public financial institutions, housing finance companies and systemically important non-banking financial companies acting as pledgee in the ordinary course of business are carved out.
Regulation 31, covered separately under promoter pledge, handles encumbrance disclosure by the promoter and runs on a seven working day clock.
Reading the stream
A Regulation 29 filing gives you an acquirer name, an aggregate holding before and after, and a transaction date. Chained over time for one company, the filings sketch how a position was built. Chained over time for one acquirer, they sketch where that acquirer has been active.
Caveats
The thresholds create blind spots by design. An acquirer can move from 5.0 percent to 6.9 percent without a fresh 29(2) filing, so the absence of a disclosure is not the absence of buying.
Persons acting in concert is a definition, not a fact you can observe. Aggregation depends on a relationship determination, and whether a set of entities was acting in concert is one of the most litigated questions under these regulations.
Two working days is fast for a regulatory filing and slow for a trade. The filing date and the transaction date differ, and a point-in-time dataset must key on the former.
The filings arrive as documents, not as a table. Turning them into a usable series means parsing exchange filing text, and the fields are not consistently structured across companies or years.