SAST vs PIT disclosures: what's the difference?

What SAST disclosures cover

SAST disclosures track substantial holdings: who owns a big block of a listed company, and when that block changes hands. Under Regulation 29 of the SAST Regulations, any acquirer who crosses 5% of voting rights must disclose it, and after that every change of 2% or more, up or down, must be disclosed again. These are blunt, mechanical triggers: they fire on the size of the position, not on who you are.

The point of the 5%-and-2% machinery is to make stake-building visible. An acquirer cannot quietly assemble a controlling block in the dark; each step past the thresholds is a public filing. And the regime escalates: keep buying past 25% and you trip the open offer obligation entirely.

SAST also carries the pledge regime. Under Regulation 31, promoters must disclose shares they have encumbered — pledged as collateral, placed under a non-disposal undertaking, and so on. Pledge disclosures are some of the most information-dense filings on the exchange, for reasons we get to below.

What PIT disclosures cover

PIT disclosures track insiders, not block sizes. Under Regulation 7 of the Prohibition of Insider Trading Regulations, promoters, directors, and the company’s designated persons must report their trades when the value crosses ₹10 lakh in any calendar quarter — whether in one transaction or several added together. The disclosure goes to the company within two trading days, and the company passes it to the exchanges.

The logic is different from SAST. PIT is not interested in how concentrated ownership is; it is policing the risk that the people closest to the company are trading on what they know before the market does. A director buying ahead of a strong quarter, or selling before a bad one, is exactly the behaviour the regime is built to surface.

How to read them side by side

Read together, the two regimes answer two different questions. SAST tells you whether someone is accumulating — building toward control, or unwinding a large position. PIT tells you whether insiders are putting their own money behind the stock, in either direction.

The same trade can appear in both. A promoter adding to their holding is an insider under PIT and may also cross a SAST threshold, so two filings land for one purchase. That is not duplication — each is measuring something the other does not. The SAST filing tells you the stake moved; the PIT filing tells you it was an insider who moved it.

Where these filings appear

Both regimes route through the same place: the company files with the stock exchanges, and the disclosures are public on the NSE and BSE corporate-announcement pages, free and timestamped. SEBI hosts them too. There is no privileged early access — the filing that hits the exchange is the filing everyone sees at the same moment, which is precisely why the speed of reading them matters.

What patterns matter

A single filing rarely means much. The pattern across quarters is what matters. The pattern to watch on the way up is sustained creeping acquisition: a promoter adding shares quarter after quarter, each move staying inside the 5%-a-year SAST allowance. Slow, deliberate accumulation often precedes a corporate action.

The pattern that warns of trouble is rising promoter pledge levels. A high or climbing pledge under Regulation 31 is a classic distress flag: if the stock falls, the lender can issue a margin call and force the sale of the pledged shares, which pushes the price down further. That feedback loop has driven some of the sharpest single-day declines on the Indian market. Telling a creeping build-up or a swelling pledge apart from the routine quarterly noise is what materiality scoring is for — our methodology sets out how each disclosure is ranked.

Promoter and insider activity runs through our corporate-governance digests, filtered so a quarter’s worth of routine PIT reports never buries the one filing that actually moves a stock.