# SEBI: off-market sale of unlisted shares to 200 buyers not public issue 2026-08-08T11:46:52+00:00 | Governance | Indian Opinion Desk Corroboration: 1 independent outlet Markets regulator SEBI on Friday clarified that an existing shareholder selling unlisted equity shares through private negotiations to up to 200 purchasers in a financial year will not be treated as a deemed public issue. The guidance came in an informal letter to IDBI Bank, which had sought clarity on its proposed divestment of unlisted investments to non-qualified institutional buyers through off-market transactions, The Hindu reports. SEBI said these are secondary transfers by an existing shareholder, not an offer by the company, so public issue rules do not apply as long as the buyer limit is met. The regulator added that contractual rights such as right of first refusal for promoters can be honoured, and transfers to qualified institutional buyers are excluded from the 200-person count. ## Coverage - thehindu.com Tags: IDBI Bank, off-market transfer, public issue, regulatory clarification, SEBI, unlisted shares Canonical: https://indianopinion.org/sebi-off-market-sale-of-unlisted-shares-to-200-buyers-not-public-issue/ License: Summary and commentary (c) Indian Opinion, reusable with attribution. Facts belong to the linked sources. Cite: https://indianopinion.org/sebi-off-market-sale-of-unlisted-shares-to-200-buyers-not-public-issue/#story-in-brief Review state: restored archive article, accurate at time of publication, not offered to search indexes.