| Legal Structure |
Three separate acts with overlapping provisions and outdated language. ​ |
Single consolidated code repealing all three acts for uniformity and simplification. ​ |
| SEBI Board Size |
Up to 9 members including Chairperson. ​ |
Expanded to up to 15 members with mandatory interest disclosure. ​ |
| Definition of Securities |
Narrower, excluding some modern instruments like hybrid securities. ​ |
Broadened to include hybrid instruments, electronic gold receipts, and "other regulated instruments". ​ |
| Enforcement & Violations |
Mixed criminal/civil penalties; no timelines or limitation periods. ​ |
Decriminalizes minor/procedural violations to civil penalties; 8-year limitation for investigations; fixed timelines. ​ |
| Investor Protection |
Limited statutory grievance mechanisms. ​ |
Mandatory investor charters, grievance redressal, and Ombudsperson system. ​ |
| Regulatory Process |
Less consultative; no separation of fact-finding and adjudication. ​ |
Transparent consultative rule-making; arm's-length separation in enforcement. ​ |
| Market Infrastructure |
Limited delegation and interoperability provisions. ​ |
SEBI delegation to MIIs/SROs; promotes interoperability and innovation sandbox. ​ |
