Q2 FY27 Results Under SEBI LODR Regulation 33: Deadlines and Disclosure

India's July–September 2026 results season gets underway in the second week of October, with the IT majors setting the tone as they always do. The mechanics of SEBI LODR Regulation 33 are familiar: prescribed formats, a 45-day clock, board approval and the limited review report filed together. What's moving this quarter sits one layer down, in how segment notes are being drawn, how related-party tables are being presented, and how BRSR-linked metrics are migrating into investor decks ahead of a widening assurance mandate.

Auditors, analysts and proxy advisors read these filings line by line. The gap between what Regulation 33 technically requires and what good disclosure practice now demands is where most of the interesting judgement calls sit.

The quarter in context: a muted base, a rebound thesis

IT stocks ran up into the print. Nifty IT advanced as companies prepared to report, with Business Standard reporting that shares "zoomed on Thursday ahead of their second-quarter results," with the index "advancing 2.1 per cent during intra-day deals." The same report placed the start of the IT earnings season for Q2 FY27 on Thursday, 8 October 2026, with Tata Consultancy Services (TCS) scheduled to announce its September-quarter results that day, board approval of standalone and consolidated numbers included, alongside consideration of a second interim dividend. That dividend detail needs confirming against the company's own exchange intimation closer to the date.

The underlying demand picture analysts are working with is not especially upbeat. Kotak Institutional Equities, as reported by Business Standard, flagged that demand conditions have "neither improved nor deteriorated since the June 2026 quarter," expecting another muted quarter for large IT companies with HCL Technologies the notable exception, Tech Mahindra leading growth among hybrids, and mid-tier names — Persistent Systems, Coforge and Mphasis — reporting the stronger numbers. Consensus estimates pencil in sequential constant-currency growth of negative 0.5 per cent to 3 per cent for large-caps this quarter.

That tepid read sits on top of an already soft FY26. Business Standard's preview of the year-ago quarter captured a pattern that has essentially persisted: corporate revenue and net profit growth both running in "single digits" for close to ten consecutive quarters. Banks were flagged as "the biggest laggards," a drag that matters because, the report noted, lenders "account for nearly a third of total corporate profits." IT services companies, the same report observed, were on track to extend "the trend of the past eight quarters" of low single-digit growth.

Key number: 45 — the number of days SEBI's Regulation 33 gives a listed entity to file its quarterly financial results after quarter-end, with 60 days allowed for the year-end results.

The forward-looking case rests on brokerages reading this stretch of mid-single-digit growth as a trough rather than a plateau. CLSA's analysis of listed non-government, non-financial companies, covered by Business Standard, projected sales growth for its coverage universe rising to 11.6 per cent in FY27, sharply higher than 6.9 per cent in FY26, with PAT growth climbing to 17.2 per cent, as wholesale price inflation is expected to rise from under 1 per cent in FY26 to around 3 per cent in FY27. CLSA analysts Nikhil Gupta and Adarsh Agarwal also pointed out that Ebitda margins have stayed close to a multi-year high of roughly 19 per cent through H1 FY26, and that large companies, those with annual sales above ₹1,000 crore, have continued to take share, from 87.6 per cent of total sales in the pre-demonetisation period to 93.1 per cent in H1 FY26. Whether that concentration shows up more plainly in segment notes this quarter is one of the things worth watching.

What does SEBI LODR Regulation 33 require for Q2 FY27 results?

Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 is the provision that governs the form, content and timing of a listed entity's financial results. It requires quarterly financial results within 45 days of quarter-end (other than the last quarter) and annual results within 60 days of year-end, in formats SEBI has separately prescribed for banks and non-banks. For the September 2026 quarter, that puts the filing window on the standard 45-day count from 30 September 2026.

The regulation has been amended piecemeal since 2015. The original formats circular, CIR/CFD/CMD/15/2015, set out Annexure I for non-bank entities and Annexure II for banks, and a 2016 circular, CIR/CFD/FAC/62/2016, layered on the Statement on Impact of Audit Qualifications for modified audit opinions.

A more recent addition, Regulation 33(3)(j), effective 15 July 2023, deals with newly listed entities: such a company must submit results for the quarter or financial year immediately following the period disclosed in its IPO offer document, following the standard 45/60-day timelines or within 21 days of listing, whichever is later. NSE's own FAQ on Regulation 33 compliance, updated in November 2025, confirms that SME companies submitting results voluntarily must still provide half-yearly figures where applicable — a reminder that "voluntary" compliance still carries format obligations once a company opts in.

None of this is new. For the clause-level detail on the format, the deadline count and the closed signatory list in Regulation 33(2)(b), see our walkthrough of the Regulation 33 quarterly results format and who signs.

The judgement this quarter lives in three places: segment notes, related-party tables, and the ESG metrics increasingly sitting alongside the numbers in investor decks.

Segment disclosure: the CODM test is still the fight

Ind AS 108 ties operating segments to how the Chief Operating Decision Maker (CODM) reviews the business, not to how investors or analysts would prefer to slice it. That mismatch is a recurring friction point every results season, and it sharpens whenever a company diversifies or reorganises its internal reporting lines without changing its external segment note to match. A conglomerate that manages capital allocation across three or four internally tracked businesses but continues to report two external segments is inviting the audit committee, and eventually the regulator, to ask why the external disclosure hasn't caught up with the internal one.

This quarter's test case is less about new companies than about existing diversified groups whose internal MIS has evolved faster than their external reporting. Where a company has added a materially new business line, or restructured reporting verticals, the segment note is the first place analysts look for whether the CODM-based definition still holds, and whether comparative figures have been restated consistently.

In practice: before the segment note goes to the audit committee, ask whether the internal MIS pack the CODM reviews still maps one-to-one to the external segments in the Reg 33 filing. If it doesn't, the note needs updating, not the MIS pack.

Related-party presentation: the gap between the note and the Reg 23 filing

Related-party transactions are the second recurring friction point. Ind AS 24 governs what goes into the financial statement note; Regulation 23 of the LODR Regulations governs the separate, more granular related-party transaction (RPT) disclosure filed with the stock exchange and reviewed by the audit committee. The two documents serve different audiences and different levels of granularity, but they're read together by analysts and proxy advisors, and inconsistencies between the aggregate figures in the quarterly results note and the transaction-level detail in the Regulation 23(9) filing are among the first things a diligent analyst will flag.

The practical issue this quarter, as in most quarters, is timing and materiality threshold alignment. Omnibus approvals obtained at the start of the year can run ahead of actual transaction values by the time Q2 numbers are finalised, and companies that haven't refreshed their omnibus approval against revised volume estimates risk a technical breach that shows up as a qualification point in the secretarial audit rather than in the financial results themselves. Getting the related-party note in the Reg 33 filing to reconcile cleanly with the RPT disclosure already on the exchange website is a basic hygiene check that is still missed more often than it should be. This is the part most secretarial teams underweight, because the two documents are owned by different people on different timelines.

A single mismatched related-party figure between the quarterly note and the Regulation 23 filing can undo months of otherwise clean governance signalling.

BRSR-linked KPIs are showing up where they didn't before

The shift here is about anticipation rather than compliance. The Business Responsibility and Sustainability Report (BRSR) is an annual-report disclosure under LODR Regulation 34, not a Regulation 33 requirement. SEBI's assurance mandate for BRSR Core — the assured subset of nine ESG attributes with prescribed KPIs and measurement methods — has been on a phased glide path widening the universe of companies required to obtain reasonable assurance, moving from the largest listed companies by market capitalisation toward a much broader set over successive financial years. We have not independently re-verified the exact circular reference or the precise company count for each year in this edition, and CFOs and company secretaries should confirm the current phase-in schedule directly against SEBI's website before relying on it. The direction of travel, toward reasonable assurance covering a much larger share of the listed universe, is well established; our explainer on BRSR Core and its nine attributes sets out what each KPI measures, and the FY 2026-27 assurance checklist covers what the 501-to-1,000 band needs in place.

What's new this quarter is practice, not rule. Investor presentations accompanying Q2 results are increasingly carrying a slide or two of BRSR Core-style metrics — emission intensity, water withdrawal, employee attrition and safety incidents — presented alongside the quarterly P&L, well ahead of the annual report in which those numbers will eventually need to reconcile. Companies anticipating a widening assurance net appear to be getting their investor-facing ESG narrative consistent with what external assurance providers will eventually test, rather than waiting for the annual BRSR filing to introduce metrics cold. We'd read that as sensible sequencing, provided the data lineage holds.

It creates its own reconciliation risk. A KPI quoted in an October investor presentation needs to tie out, numerically and in scope, to the same KPI as it eventually appears in the BRSR filed with the annual report some months later, and, where assurance applies, to the assurance provider's basis of preparation. Sustainability and IR teams that treat the investor-deck number and the annual-report number as separate workstreams are setting up next year's awkward question from an analyst who tracked the two across filings. If you're unsure whether your entity even falls inside the BRSR net this year, the three-layer applicability test works through the thresholds.

A practitioner's checklist for this quarter's filings

• Confirm the segment note's CODM basis still matches how the business is being managed internally, especially where a new vertical or restructuring has occurred since the last annual report.
• Reconcile the related-party aggregate in the quarterly results note against the Regulation 23(9) disclosure already filed with the exchange; flag any omnibus approval that is running ahead of its sanctioned value.
• Where investor presentations carry BRSR Core-style metrics, keep a controlled master file so the same figure, on the same scope and boundary, can be traced forward into the annual BRSR filing.
• Verify signatory requirements on the Reg 33 filing: the authorisation and the limited review report from the statutory auditor, filed together, not as separate submissions.
• Check the newly listed entity timeline under Regulation 33(3)(j) for any portfolio company that listed in the last twelve months; the 21-days-from-listing fallback is easy to miss in a busy IPO calendar.
• Cross-check exceptional item classification and the Statement on Impact of Audit Qualifications format wherever the auditor's opinion carries any modification.
• Build in a buffer before the 45-day deadline for the audit committee and board sign-off cycle; a late filing attracts an exchange fine regardless of how minor the delay.

What this means for CFOs, company secretaries and IR teams

For CFOs, the Q2 close is the moment to pressure-test whether the segment structure reported externally still reflects how capital and resources are being allocated internally. Waiting until the annual report to fix a stale segment note means a full year of analyst questions in between.

For company secretaries, the related-party reconciliation between the Reg 33 note and the Regulation 23 filing deserves its own checklist item in the board meeting pack, separate from the standard LODR compliance certificate, given how easily omnibus approval values drift from actual transaction volumes over two quarters. It's also worth reading this quarter's filing against the wider set of changes SEBI has been pushing through: our note on the SEBI board meeting of 24 September 2026 sorts the thirteen approved items into what is law, what is coming and what is still consultation.

For IR teams building the investor presentation, the discipline is simple in principle and harder in practice: any ESG metric that appears in an investor deck this quarter should already be traceable to the same data source, scope and boundary that will feed the annual BRSR filing, because the assurance net is only getting wider from here, and an inconsistent number discovered after the fact is a worse outcome than a more conservative number disclosed early.

The quarter ahead will be read, as always, for growth and margin. Treat the segment note, the related-party reconciliation and the ESG master file as part of that same sign-off, not as paperwork to clean up once the annual report season arrives.