Navigating the Waters of Change: SEBI’s Instant Settlement Plan and Foreign Investor Concerns

[Arihant Sethia is a student at the Gujarat National Law University]

In the fast-paced world of financial markets, where time is often equated with value, the Securities and Exchange Board of India (SEBI) has set the stage for a groundbreaking transformation. The proposed shift from the T+1 settlement system to an instantaneous settlement framework represents a bold leap into the future, positioning India at the forefront of global financial innovation. This visionary move, announced by SEBI Chairperson Madhabi Puri Buch, aims to revolutionise the settlement landscape by drastically reducing the time required for investors to receive proceeds from their trades.

Beyond mere efficiency gains, SEBI’s proposal seeks to augment the attractiveness of India’s financial markets for both domestic and international investors. Accelerating settlement times to within a single hour promises to unlock plenty of advantages, from heightened market efficiency to a significant reduction in settlement risks.

As India stands on the cusp of this paradigm shift, it is crucial to delve into the multifaceted dimensions of the proposed instant settlement plan. However, amid the optimism surrounding the potential benefits, concerns have emerged, particularly from foreign investors. This post navigates through the challenging waters of SEBI’s instant settlement plan, shedding light on its advantages and addressing the concerns raised by global investors.

Advantages of Shifting to SEBI’s Instant Settlement Plan

SEBI’s proposed transition from the T+1 settlement system to an instantaneous settlement plan heralds a new era for India’s financial markets, bringing forth a host of advantages that promise to reshape the investment landscape. Accelerating settlement times to within one hour is poised to enhance market efficiency significantly. By streamlining the transaction process, investors can access their assets swiftly, enabling quicker reinvestment of funds and fostering a dynamic, responsive market environment.

The move towards instant settlement minimises settlement risks associated with counterparties and market fluctuations. The shortened timeframe for settling trades reduces the window during which financial commitments are open, thereby mitigating potential disruptions and enhancing overall market stability. Furthermore, swift settlement contributes to increased liquidity within the market. Investors, both institutional and individual, can readily reinvest their funds, promoting a more dynamic trading environment. This heightened liquidity not only benefits traders but also adds to the overall robustness of the financial ecosystem. However, amidst the optimism, it is essential to acknowledge and address the concerns raised by foreign investors to ensure a smooth and inclusive transition.

Drawbacks of SEBI’s Instant Settlement Plan from Foreign Investors’ Perspective

While SEBI’s proposed shift to an instantaneous settlement plan promises significant advantages for India’s financial markets, it is not without its challenges, particularly from the standpoint of foreign investors. The concerns raised by global market participants shed light on potential drawbacks that warrant careful consideration.

Operational Challenges

Foreign investors, often operating in different time zones, face significant operational challenges with the proposed instant settlement plan. Aligning with multiple market timings and navigating the absence of a standardized global settlement system can result in operational inefficiencies and complexities for investors operating across borders.

Regulatory Hurdles

The diversity of regulations in foreign investors’ home countries poses a considerable hurdle. Complying with SEBI’s evolving instant settlement requirements while adhering to distinct regulatory frameworks abroad may prove to be a complex and burdensome process. Harmonizing these disparate regulatory landscapes is crucial for a seamless transition.

Potential Increased Costs

The implementation of an instant settlement system could lead to increased costs for foreign investors. Adapting to the new requirements may necessitate significant upgrades to existing systems and processes, potentially outweighing the benefits of faster settlement times. This cost factor may deter foreign investors and hinder the anticipated surge in global capital inflow.

Pre-Funding Requirements

With same-day settlement, foreign investors may need to pre-fund all transactions a day prior to the trade, introducing an additional layer of complexity. This requirement increases costs, exposes investors to foreign exchange risk, and raises concerns about the tracking error of funds. It may prompt foreign investors to reassess the attractiveness of the Indian market.

Fragmentation of Liquidity

The introduction of two different settlement cycles, the existing T+1 and the proposed instant settlement, poses a risk of fragmenting the liquidity of the market. This fragmentation may lead to inconsistent liquidity levels, potentially impacting trading patterns and introducing an element of unpredictability for foreign investors.

As India navigates the complexities of transitioning to instant settlement, addressing these drawbacks from the perspective of foreign investors is paramount. A collaborative approach involving stakeholders, regulatory bodies, and market participants can help find solutions to these challenges, ensuring a smooth and inclusive transformation.

Addressing Drawbacks of SEBI’s Instant Settlement Plan for Foreign Investors

As SEBI steers the course towards an instantaneous settlement plan, it becomes imperative to proactively address the legitimate concerns raised by foreign investors. Recognizing the challenges and mitigating potential drawbacks is crucial for ensuring a smooth transition that not only aligns with India’s financial ambitions but also upholds its commitment to being an attractive global investment destination.

Engage in Collaborative Dialogue

To build a comprehensive understanding of foreign investors’ concerns, SEBI should initiate open and collaborative dialogue with stakeholders. This includes hosting forums, consultations, and roundtable discussions involving foreign investors, industry experts, and regulatory bodies. Engaging in direct conversations fosters a sense of transparency, allowing SEBI to gain insights into specific challenges faced by foreign investors.

Conduct Pilot Programmes

Before rolling out the instant settlement plan nationwide, SEBI could consider conducting pilot programmes. These programmes would serve as controlled environments to identify, assess, and address potential issues that may arise during the transition. Pilots provide a practical testing ground, allowing for adjustments based on real-world scenarios before the system is implemented on a larger scale.

Provide Flexibility in Implementation

Recognizing the diverse operational capacities and constraints of foreign investors, SEBI should explore providing flexibility in the implementation of the instant settlement plan. This could involve allowing foreign investors to opt-in or opt-out based on their preferences and capabilities. Flexibility ensures that investors can gradually adapt to the new system, mitigating sudden operational challenges and reducing the risk of disruptions.

Offer Financial Incentives

To alleviate concerns about potential increased costs, SEBI could consider offering financial incentives to foreign investors. This could take the form of subsidies or tax breaks aimed at offsetting the expenses associated with upgrading systems and processes to comply with the new settlement requirements. Financial incentives act as a strategic measure to encourage foreign investors to participate actively in the Indian market.

Provide Technological Assistance

Acknowledging the technological upgrades required for seamless integration into the instant settlement system, SEBI could offer technological assistance to foreign investors. This might involve collaboration with technology providers or facilitating knowledge-sharing platforms to help investors upgrade their systems efficiently. By bridging the technological gap, SEBI ensures that foreign investors can adapt more smoothly to the new settlement paradigm.

Harmonize Regulatory Frameworks

Addressing the regulatory hurdles requires a concerted effort to harmonize frameworks. SEBI should work in collaboration with regulatory authorities in foreign investors’ home countries to streamline compliance processes. Creating a cohesive regulatory environment ensures that investors can navigate seamlessly between different jurisdictions, reducing the complexity and burden associated with adhering to disparate regulatory requirements.

Continuous Monitoring and Evaluation

Post-implementation, SEBI should institute a robust system of continuous monitoring and evaluation. This involves closely tracking the performance of the instant settlement plan and actively seeking feedback from foreign investors. Regular assessments allow for timely adjustments, ensuring that any emerging issues are promptly addressed to maintain the system’s efficiency and effectiveness.


In navigating the uncharted waters of transitioning from T+1 to an instantaneous settlement system, SEBI’s visionary approach has sparked excitement and anticipation within India’s financial landscape. The advantages of heightened market efficiency, reduced settlement risks, and increased global competitiveness are undeniable. However, as we tread this transformative path, it is essential to acknowledge the genuine concerns voiced by foreign investors.

SEBI’s commitment to addressing these challenges through collaborative dialogue, pilot programmes, flexibility in implementation, financial incentives, technological support, and regulatory harmonization underscores its dedication to a seamless transition. Striking a delicate balance between innovation and inclusivity, SEBI’s efforts are poised to position India as a global financial hub that not only embraces cutting-edge practices but also nurtures a welcoming environment for international investors. Through these collective efforts, India stands poised to not only transform its financial markets but also emerge as a beacon of progressive, inclusive, and resilient economic growth on the global stage.

Arihant Sethia

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