Regulation 33 Quarterly Results: Format, 45/60-Day Deadline and Who Signs

Three separate things get muddled every quarter in board papers and compliance checklists: the format quarterly results must follow, the deadline they must meet, and the person legally entitled to put a signature on the statement. Regulation 33 of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 answers all three. Regulation 33 is the LODR provision that governs how, in what form and by when a listed entity submits its financial results to the stock exchanges.

NSE's dedicated FAQ document dated 17 November 2025 on filings under Regulation 33 is a good occasion to take the three threads apart, because the edge cases it deals with (IPO entities, migration from the SME board, paid-up capital crossing ₹25 crore) only make sense once the format, the clock and the signatory rule are each understood on their own terms.

What format must Regulation 33 quarterly results follow?

The line-item structure that every listed company's quarterly results follow (revenue from operations, other income, total expenses, profit before tax, tax expense, profit after tax, other comprehensive income, paid-up equity capital, earnings per share) was prescribed by SEBI through Circular CIR/CFD/CMD/15/2015 and has been carried forward into Regulation 33 and its annexures. It is not a template a company can redesign. It is a mandated presentation, which is why every quarterly filing on the exchanges, whatever the sector, uses visually identical headings.

A few obligations sit inside that format and get missed. Where a listed entity has subsidiaries, associates or joint ventures, it must submit consolidated results in addition to standalone ones, and the NSE FAQ is explicit that if the entity leaves any of these out of consolidation, it must give a detailed explanation in the notes. Segment disclosure is not waived for a company operating in a single business segment; the NSE FAQ confirms it applies to single-segment entities too.

For the last quarter of the year, Regulation 33(3)(e) requires a specific note: that "the figures for the last quarter are the balancing figures between audited figures in respect of the full financial year and the published year-to-date figures up to the third quarter of the current financial year." That note is the root of the "unaudited Q4" confusion dealt with below.

SME companies get a partial carve-out, though not the one many assume. They may voluntarily choose to file quarterly, but half-yearly figures are mandatory either way, per the November 2025 FAQ. And if an SME's post-issue paid-up capital is set to cross ₹25 crore under the proviso to Regulation 280 of the SEBI (ICDR) Regulations, 2018, quarterly filing stops being voluntary and becomes mandatory from the quarter in which the allotment crossing that threshold falls on or before the due date for that quarter's results.

Key number: ₹25 crore, the post-issue paid-up capital threshold that converts an SME's voluntary quarterly filing into a mandatory one under the Regulation 280 ICDR proviso.

The 45-day and 60-day clock, mapped to real dates

Regulation 33 runs on two timelines. Quarterly and year-to-date standalone results are due within 45 days of the end of each quarter, other than the last quarter of the financial year. The annual audited results are due within 60 days from the end of the financial year. NSE's compliance calendar converts this into fixed dates that every secretarial calendar should already carry: 14 August for the quarter ended June, 14 November for the quarter ended September, 14 February for the quarter ended December, and 30 May for the audited annual results for the year ended March.

The 30 May date is the one that drives everything downstream, including the annual report build and the AGM timetable.

When does a newly listed company's clock start?

The 45/60-day rule assumes the company has been listed through a full reporting cycle. For entities that have just listed through an IPO, Regulation 33(3)(j) applies instead, and NSE's FAQ sets out the mechanics cleanly: the entity submits financial results for the quarter or year immediately following the period already disclosed in the offer document, by whichever is later of the standard 45/60-day due date or 21 days from the date of listing.

In the FAQ's own illustration, a company listed on 10 August for the first quarter (April to June) ends up with a due date of 31 August, driven by the 21-day rule rather than the usual 14 August cut-off, while a company listed on 22 October for the second quarter lands on 14 November because the standard due date is the later of the two. The same later-of logic applies to entities migrating from the SME board to the main board and to entities listed through a scheme of arrangement: if the listing or migration event falls after the quarter end but on or before the due date, that quarter's results must still be filed.

Does Integrated Filing replace Regulation 33?

No, and this is the misconception doing the most damage to compliance calendars right now. Integrated Filing is a submission mechanism, not a new disclosure regime: it bundles three existing filings into a single window.

NSE's compliance calendar for the main board describes "Integrated Filing - Financials" as comprising the Regulation 33(3)(a) financial results together with the limited review or auditor's report, the Regulation 23(9) disclosure of related-party transactions, and the Regulation 32(1) statement of deviation or variation, all filed within the same 45-day (quarterly) or 60-day (last quarter and annual) window Regulation 33 already prescribed. The content obligations under Regulation 33, meaning the format, the signatory requirement and the segment and consolidation notes, are untouched. What changes is the plumbing: one XBRL-based filing replacing several separate uploads, in effect from the quarter ended 31 December 2024 under NSE's facilitation circular.

Treating Integrated Filing as a replacement for Regulation 33 leads companies to assume the signatory or format rules moved as well. They didn't.

Why "unaudited Q4" is a contradiction in terms

Practitioners often say "Q4 unaudited results" the way they say Q1, Q2 and Q3 unaudited figures subject to limited review. There is no such filing.

Results for the first three quarters may be either audited or unaudited and subject to limited review, at the company's option, under Regulation 33(3)(a). The fourth quarter has no independent existence in the filing regime: what gets published for Q4 is derived arithmetically from the audited annual results, which are mandatorily audited and due within 60 days of the financial year end. The required note is the balancing-figures disclosure described above, full-year audited numbers minus the nine-month year-to-date figures already published.

Any "Q4 results" press release is, strictly, an extract of the audited annual statement rather than a standalone unaudited submission. Calling it unaudited misstates both its legal basis and its audit status.

Who signs quarterly financial results under Regulation 33?

Regulation 33(2)(b) states, in terms SEBI's own April 2025 consolidated FAQ repeats verbatim, that financial results submitted to the stock exchange "shall be signed by the chairperson or managing director, or a whole-time director or in the absence of all of them it shall be signed by any other director of the listed entity who is duly authorized by the board of directors."

The list is closed. It does not include the Chief Financial Officer, the Company Secretary or the Chief Executive Officer, unless that CEO also holds one of the four listed board positions. A company secretary who lets the CFO sign a Regulation 33 statement has created a defect in the filing itself rather than a drafting slip, and we'd read an exchange query on that as a question of validity, not housekeeping.

Where the CFO myth comes from

The confusion is understandable, because the CFO does have a statutory role in the same process, just not a signing one. Before the results go to the board, the regulation requires the CEO and the CFO to certify to the board that the figures "do not contain any false or misleading statement or figures and do not omit any material fact which may make the statements or figures contained therein misleading." That is certification to the board, an internal control step, and a different act from signing the statement that goes out to the exchange.

The second source of confusion is the Companies Act, 2013. Section 134(1) requires the board's report and financial statements to be signed by the chairperson (if board-authorised) or by two directors including the managing director, along with the CEO, CFO and company secretary wherever appointed. That is a different document under a different statute, sitting inside the annual report stack rather than the quarterly filing. Conflating the two leads companies to assume the CFO's name belongs on the Regulation 33 statement too.

In practice: Before every quarterly board meeting, get written confirmation of which director will sign if the chairperson, MD and whole-time director are all unavailable on signing day. A standing board resolution naming a backup signatory, refreshed annually, avoids a hunt for an "authorised director" an hour before the filing deadline.

The Regulation 33 and Regulation 52 signatory gap for debt-listed entities

Entities with only listed non-convertible securities report under Regulation 52 rather than Regulation 33, and the signatory rule there has historically been narrower. Regulation 52(2)(b), as SEBI's October 2024 consultation paper on Ease of Doing Business quotes it, requires only that quarterly results "be taken on record by the board of directors and signed by the managing director/ executive director": no chairperson option, no whole-time director option, and no fallback to any other director duly authorised by the board if the MD or executive director is unavailable.

SEBI's paper flags the gap directly, noting that Regulation 33(2)(a) and (b) requires board approval and signing by "the chairperson or managing director, or a whole time director or in the absence of all of them, by any other director duly authorized by the board of directors," while Regulation 52(2)(b) does not extend that flexibility. The paper proposes amending Regulation 52(2)(b) to mirror Regulation 33(2)(b) exactly, "to ensure parity between provisions under LODR Regulations for equity and debt listed entities."

As of that consultation paper, this is a proposal and not confirmed as notified into the regulation text. Proposals of this kind only bind once gazetted, so companies with listed debt should verify the current operative wording of Regulation 52(2)(b) before assuming the broader Regulation 33 list already applies to them. The LODR text does move in places teams rarely re-read, as the 2026 rewrite of Regulations 39 and 40 showed.

What this means for CFOs, company secretaries and IR teams

Company secretaries should audit the board resolution register now rather than at the next results meeting, to confirm there is a current, valid authorisation naming a specific director as backup signatory under Regulation 33(2)(b), instead of a vague reference to "any director." This is the part most secretarial teams miss until the signing day itself.

CFOs should treat the certification to the board as the full extent of their statutory role in the signing chain and leave the exchange-facing signature to the chairperson, MD, whole-time director or the authorised director.

IR teams drafting press releases around the fourth quarter should stop describing those numbers as "unaudited" in investor communications. They are extracted from audited annual figures and should be labelled accordingly, with the balancing-figures note carried through into any investor-facing summary.

Entities with listed debt should check whether their Regulation 52(2)(b) signatory list has been formally amended before assuming parity with equity-listed peers. Newly listed companies, whether by IPO, SME migration or scheme of arrangement, should build the later-of 21-day and 45/60-day rule into their first post-listing compliance tracker rather than defaulting to the standard quarterly date.

None of this needs new systems or new templates. It needs the plain text of Regulation 33(2)(b) and Regulation 52(2)(b), the board resolution that names the authorised signatory, and a clear line in your head between the Integrated Filing mechanics and the substantive disclosure obligations that haven't moved at all.