sebi
Published on 16 July 2025
SEBI's New Data Sharing Policy for Market Infrastructure Institutions
SEBI’s New Data Sharing Framework: Balancing Transparency, Research, and Investor Privacy
In a carefully calibrated move that seeks to harmonise transparency with data protection, the Securities and Exchange Board of India (SEBI) has introduced a structured framework governing how Market Infrastructure Institutions (MIIs) can share data with external parties. Released via a circular on December 20, 2024, the framework applies to stock exchanges, clearing corporations, and depositories, and is designed to support academic research while guarding against misuse of investor-linked information.
By codifying what data can be shared, how it should be classified, and what conditions apply to access, SEBI aims to eliminate ambiguities that have long hindered responsible financial research in India.
The Heart of the Framework: Classifying Data, Protecting Privacy
SEBI has asked all MIIs to segregate their datasets into two broad categories: information that can be freely shared, and data that requires tighter control.
Publicly Shareable Data
This includes non-sensitive, aggregated information such as:
- Market-wide turnover and trading volumes
- Historical index and sector performance
- Public corporate actions and announcements
- General order book and price trend data
Restricted Data
Classified as sensitive, these datasets carry the risk of re-identification or indirect exposure of investor activity, even if names are excluded.
Examples include:
- KYC details or personal identifiers
- Trade execution logs and timestamp records
- Broker-level trading analytics
- Client portfolios or holding data (even in anonymized form)
This information will only be released after SEBI-mandated reviews and may require confidentiality undertakings from researchers. The core principle: if a person or institution can be inferred from the data, it's not public.
The Cost of Access: SEBI’s Fair-Use Approach
The circular introduces a tiered cost model to balance accessibility with administrative efficiency.
| Request Type | Criteria | Cost |
|---|---|---|
| Basic Requests | ≤ 2 GB/year | Free (for accredited researchers) |
| Complex Requests | Involving anonymization, system linkages, or large datasets | Cost-recovery basis only (no profit allowed) |
Researchers must declare their purpose and scope of analysis in advance, helping MIIs assess feasibility and risks.
Compliance Timeline for MIIs
| Milestone | Deadline |
|---|---|
| Classify all datasets | By February 18, 2025 |
| Submit internal policy to SEBI | Same date |
| Begin accepting requests under new norms | After SEBI approval |
SEBI will monitor implementation closely, and institutions that fail to comply could face regulatory escalation.
Why SEBI Is Acting Now
India’s capital markets are evolving rapidly, with academic research and data analytics playing a growing role in shaping both policy and investor behaviour. Yet, access to structured data—especially for independent researchers—has remained fragmented and opaque.
At the same time, investor privacy risks have grown, with some anonymized datasets shown to be vulnerable to reverse-engineering.
By moving toward a standardised and ethics-driven model, SEBI aims to:
- Level the playing field for researchers
- Curb data misuse
- Reinforce trust in the digital backbone of Indian markets
The policy draws from best practices globally, aligning with the EU’s GDPR norms, OECD anonymisation guidelines, and similar data governance principles adopted by regulators in Singapore and the United States.
A New Lens on Anonymisation
SEBI is unambiguous: stripping names isn’t enough. The risk lies in linkable data—where seemingly innocuous combinations (like timestamps in illiquid stocks) can lead to identity inference.
| Data Type | Re-Identification Risk | Classification |
|---|---|---|
| Aggregated order data | Low | Public |
| Time-based trade logs in niche segments | Medium-High | Restricted |
| Broker-level multi-instrument activity | High | Restricted |
MIIs must perform a risk check before releasing any dataset. Researchers may be required to sign data-use declarations and share a copy of their research findings with SEBI or the concerned MII.
Who Benefits—and How
For Researchers:
- Transparent application process
- Easier access to baseline market data
- Fair, standardised rules across MIIs
For MIIs:
- Regulatory clarity on what can be shared
- Defined liability boundaries
- Greater control over sensitive datasets
For Investors:
- Assurance that personal data will not be mishandled
- Protection from indirect profiling
- Confidence in ethical research frameworks
SEBI’s Broader Message
SEBI’s latest initiative is about more than just rules—it reflects a philosophy. As the Indian capital markets integrate more deeply with global research networks and data infrastructure, transparency must be matched with responsibility.
This circular underscores SEBI’s evolving regulatory vision:
- Encourage meaningful, evidence-based market research
- Empower academics without compromising privacy
- Enable access, but under informed, enforceable boundaries
Conclusion: Toward a More Trusted, Research-Driven Market Ecosystem
SEBI’s December 2024 data sharing framework offers a forward-looking blueprint for navigating the delicate intersection between open data and individual privacy. It empowers researchers and institutions, while also creating enforceable protections against misuse—marking a critical step in modernising India’s market data infrastructure.
As MIIs begin implementing the framework and researchers recalibrate their methods, the end goal remains clear: an Indian market that is not just digitally advanced, but also ethically grounded and globally respected.