Significant Beneficial Owners – Key Takeaways From Recent Regulatory Orders

In recent months, there has been a flurry of orders against companies across India on account of defaults in making "significant beneficial owner" (SBO) filings. These orders, including against the likes of LinkedIn India and Samsung India, represent the first substantive rulings on the SBO regime following its inclusion in the Companies Act a few years back. While these orders are all case-specific and some of them may well be reversed in appeal, there are a few overarching themes covered in this note which are relevant to other corporate groups.

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The last three months of May, June and July of 2024 have witnessed a flurry of orders by the Registrar of Companies in India (RoC) against various companies across the country on account of defaults in making "significant beneficial owner" (SBO) filings pursuant to the corresponding rules (SBO Rules) under the Companies Act, 2013 (Companies Act). While the order against LinkedIn Technology Information Private