SEBI's New Data Sharing Policy: Guidelines for Researchers

SEBI’s Data Sharing Framework for Market Infrastructure Institutions: A Measured Leap Towards Research-Driven Transparency

In a development that could quietly reshape how researchers, institutions, and even policymakers engage with India’s capital markets, SEBI rolled out a landmark data sharing framework on December 20, 2024, targeting Market Infrastructure Institutions (MIIs). Think of MIIs as the plumbing of the financial system—stock exchanges, clearing corporations, and depositories—entities that handle the everyday flow of transactions and information that keep the market running.

Until now, access to market data—particularly for research—was inconsistent and often entangled in ambiguity. But with this new framework, SEBI is drawing a clear boundary between what can be shared openly and what must remain protected. It’s a move that could bring long-overdue structure to how market data is handled in India.

Drawing the Line: Two Buckets of Market Data

In a rare display of regulatory clarity, SEBI has divided all MII-held data into two straightforward categories: Publicly Shareable Data and Non-Public Data. The distinction may seem simple on the surface, but it sets the tone for how market participants and researchers can approach data access from here on.

1. Publicly Shareable Data: Now Easier, Fairer to Access

This category covers data that either:

Already exists in the public domain—like closing prices, market summaries, indices, and settlement statistics,
Or is suitably anonymized to prevent identification of individual investors or firms.

Some datasets might be too large or complex to publish on a website—but they can be made available on request. That’s where SEBI’s new structure really begins to help.

For bona fide researchers, SEBI now mandates that up to 2 GB of such data per year must be made available free of charge, so long as it’s requested “as is.” Need it beyond that limit, or want it in a specially processed format? MIIs are allowed to charge—but only on a reasonable, cost-recovery basis.

Why is this significant? Because, frankly, access to credible market data has been cost-prohibitive for many academic institutions and independent researchers. This removes that barrier—at least partially—and fosters a more research-friendly ecosystem.

2. Non-Public Data: Guarded, and Rightly So

On the other side of the fence is Non-Public Data. This includes sensitive information such as:

KYC records, which could directly identify individuals,
Trade-level logs that may expose proprietary strategies,
Undisclosed shareholding patterns, or
Even anonymised data that, if poorly handled, could be reverse-engineered to reveal identities.

Access here is tightly controlled. If you’re a researcher looking to dive into this category, be prepared for approval protocols, potential non-disclosure agreements, and higher cost implications—all of which aim to protect the integrity of the market and safeguard investor privacy.

This is where SEBI seems to have struck a cautious, but sensible balance. The framework acknowledges the value of data for research while keeping guardrails in place to ensure trust in the system isn’t compromised.

The Fee Logic: Transparency Over Profit

SEBI has made it abundantly clear that MIIs are not in the business of monetising data. Any fee charged—whether for large datasets, advanced formatting, or specialised reports—must reflect the actual effort involved.

Data extraction beyond free limits? Permissible, but chargeable on a fair basis.
Complex processing or anonymisation? Again, allowed, but must be justifiable.
Customised analysis or value-added reports? Fine—but not an excuse for profiteering.

In effect, this means genuine researchers won’t be priced out of access, while frivolous or exploitative data requests can be filtered through cost deterrents.

What MIIs Are Expected to Do

The policy also puts the onus squarely on MIIs to clean up their act. By February 18, 2025, every MII must:

Submit a complete inventory of both public and non-public datasets under their control,
Justify why each dataset falls under a given category,
Disclose their fee structures, and
Ensure their data access procedures align with SEBI’s expectations on privacy, fairness, and accountability.

SEBI isn’t treating this as a one-off. The regulator will review the submissions, audit the implementation periodically, and step in if it finds lapses.

Why This Policy Is More Than Just Paperwork

For researchers, this move takes much of the guesswork out of accessing market data. Instead of navigating informal contacts or opaque permission chains, there’s now a clearly defined route—with predictable rules and limits.

For market participants, particularly traders and investors, there’s comfort in knowing their private information won’t be leaked in the name of research or analytics. That’s a critical reassurance in today’s data-sensitive world.

And for MIIs, the framework offers clarity and a single set of guidelines to follow—something that reduces legal risk and brings consistency across institutions.

Final Word: A Step Towards Smarter Markets

SEBI’s data sharing policy isn’t just a technical circular. It’s a quiet but meaningful shift in how transparency, research, and investor protection intersect in India’s capital markets.

By enabling open access where it’s safe and justified, while holding firm where privacy is paramount, the regulator is setting up a model that promotes knowledge without weakening safeguards.

If implemented in both letter and spirit, this framework could unlock deeper insights into everything from market microstructure and liquidity patterns to investor behaviour and policy outcomes.

For a market that aspires to be globally competitive and research-driven, this isn’t just welcome—it’s essential