1. INTRODUCTION
In today's era when data is known as the new oil,1 the
Securities Exchange Board of India
(“SEBI”) has taken a significant step
to transform and update the process of sharing financial market
data with the proposed draft “Policy for Sharing Data for
the Purpose of Research / Analysis” (“New
Draft Policy”).2 The New Draft Policy
seeks to not only address the limitations of SEBI's older
Data Sharing Policy, 2018 (“2018
Policy”),3 but also attempts to come
closer to the Digital Personal Data Protection Act (DPDPA),
2023, in terms of compliance.4
The journey towards the New Draft Policy began with SEBI's
2018 Policy, which sought to bring some semblance of structure to
data sharing by SEBI in Indian financial markets with
research/educational organisations and regulated entities for
conducting research/ analytics, and academic studies. Under the
2018 Policy, only historical data (two years or older) is permitted
to be shared and that too in an
