Reading a shareholding pattern: what each table and column in SEBI's format means

Most guides to the shareholding pattern list the categories (promoters, institutions, public) and say a falling promoter stake or a high pledge deserves attention. This article does something narrower: it walks through the prescribed SEBI format itself, table by table, explains what the key columns count and what they are measured against, and shows the arithmetic for comparing two quarters. It makes no reading of any shareholder’s movement. For where to find the filing on the exchange websites, see the guide to company filings.

The format has four share-count tables, plus two statements

The format sits in an annexure to a SEBI master circular and was revised by a SEBI circular dated 20 March 2025, in force from the quarter ending 30 June 2025. It is issued under Regulation 31 of the Listing Obligations and Disclosure Requirements (LODR) Regulations. Regulation 31(1)(b) requires the statement to be submitted to the stock exchanges quarterly, within twenty one days from the end of each quarter; Regulation 31(1)(a) and (c) add a filing one day before listing and one within ten days of a capital restructuring that changes total paid-up share capital by more than two per cent. For entities listed on an SME exchange the statement is half-yearly, within twenty one days from the end of each half year.

Table	What it covers
I	Summary: one row each for (A) promoter and promoter group, (B) public, (C) non-promoter non-public, with (C1) shares underlying depository receipts and (C2) shares held by employee trusts
II	The promoter and promoter group in detail: Indian (individuals and HUFs, governments, financial institutions or banks, other) and foreign (individuals, governments, institutions, foreign portfolio investors, other), with sub-totals (A)(1) and (A)(2)
III	The public shareholders in detail: domestic institutions, foreign institutions, governments, and non-institutions, with sub-totals under (B)
IV	The non-promoter non-public holders: custodians or depository-receipt holders (C1) and employee benefit or welfare trusts (C2)
V	Significant beneficial owners (a separate statement, not a share-count table)
VI	Foreign ownership limits: the board-approved limit and the limit utilised, as on the shareholding date and at the end of each of the previous four quarters

Two rules from SEBI’s LODR FAQs matter for reading the tables. First, each shareholder appears in only one category, because holdings are consolidated by PAN: promoter and promoter group, or public, or non-promoter non-public. Second, a person who belongs to the promoter group is listed in Table II even when holding no shares, and a name leaves the promoter group list only after the reclassification process in Regulation 31A is followed. A “nil” row in Table II is therefore not an error, and the March 2025 revision added a footnote in Table II pointing to the details of nil-holding promoter-group members.

What the three main groups mean

• Promoter and promoter group (A). The people and entities classed as promoters or promoter group under the ICDR Regulations, as the FAQs put it. Table II lists them by name, so the group’s total is the sum of its rows.
• Public (B). Every holder who is neither promoter, promoter group nor in the non-public set. Table III breaks it into institutions (mutual funds, insurers, banks, foreign portfolio investors and others) and non-institutions (resident individuals split at Rs 2 lakh of nominal share capital, NRIs, bodies corporate and others). The format asks for names of holders at or above 1 per cent of the listed entity’s shares.
• Non-promoter non-public (C). Shares that are neither promoter nor public: those underlying depository receipts held through a custodian (C1) and those held by employee benefit or welfare trusts (C2).

The columns that decide how a number is read

The three groups share a column layout. These are the ones that change how a figure should be compared.

1. Shares held. Fully paid-up equity shares, partly paid-up shares and shares underlying depository receipts are shown in separate columns and added into a total shares held.
2. Shareholding as a percentage of (A+B+C2). The header says this is the percentage calculated under the Securities Contracts (Regulation) Rules, 1957, with a base of A plus B plus C2. Every percentage in the main columns is a share of that one base. In the circular’s format, Table I marks this percentage column as NA on the (C1) line for shares underlying depository receipts, so those shares are not part of the percentage calculation.
3. Voting rights. Counted per class of security, with a total as a percentage of total voting rights. Where a company has one class, this tracks the share count.
4. Outstanding convertible securities. The March 2025 revision clarified that this column includes ESOPs as well as warrants, and added a column for the total number of shares on a fully diluted basis, which is shares held plus the convertible securities, and a matching percentage of diluted capital. So there are two percentages for each holder: one on shares in issue, one assuming conversion.
5. Locked-in shares. A count, and that count as a percentage of the holder’s own total shares.
6. Pledged, non-disposal undertaking, other encumbrances, total encumbered. Since the March 2025 revision, the format has separate columns for shares pledged, shares under a non-disposal undertaking, other encumbrances, and a total encumbered figure that adds the three. The format notes that “encumbrance” has the meaning given in the SEBI takeover regulations, which it refers to rather than restates. Regulation 28(3) of the SAST Regulations, 2011 (as consolidated on SEBI’s website, amended up to 5 December 2025) says the term “shall include” any restriction on the free and marketable title to shares, a pledge, lien, negative lien or non-disposal undertaking, and any covenant, transaction, condition or arrangement in the nature of an encumbrance. It is an inclusive list, not a closed definition.
7. Shares in dematerialised form. A count of equity shares held in dematerialised form. The format has no percentage column for it.

The pledge percentage has a different base

For the locked-in and encumbered columns, the percentage column is headed “as a % of total shares held”. The base is the holder’s own shares, not the company’s capital. A promoter holding with 10 per cent encumbered means ten per cent of that promoter’s shares, which is a much smaller share of the company. The format also says the encumbrance columns (XIV to XVII in the public and non-promoter non-public tables) are not applicable there; they are filled in for the promoter and promoter group in Table II and in the summary row (A) of Table I.

An illustrative two-quarter comparison

The figures below are invented to show the arithmetic. They are not drawn from any company.

	Quarter 1	Quarter 2
Shares in issue (A+B+C2)	100,000,000	102,000,000
Promoter and promoter group shares	60,000,000	60,000,000
Promoter and promoter group, % of shares	60.00%	58.82%
Shares encumbered (total)	6,000,000	6,000,000
Encumbered, % of promoter holding (column b)	10.00%	10.00%
Encumbered, % of total shares in issue	6.00%	5.88%

The percentage in the promoter row fell from 60.00 to 58.82 per cent, a change of 1.18 percentage points, yet the promoter share count did not change. The only change in the table is the denominator, which rose by 2,000,000 shares. This is why a quarterly comparison should be done in this order.

1. Compare the share counts first. Subtract the earlier quarter’s shares held from the later quarter’s for each group. A change in the count means shares moved; no change in the count means any change in the percentage came from the base.
2. Compare the base. Subtract the earlier quarter’s total shares in the (A+B+C2) base from the later quarter’s. A rise can reflect new shares issued by the company or other changes in what falls inside the base; the filing itself does not say why, and any explanation sits in the company’s other announcements.
3. Convert pledge to the same base. Multiply the encumbered percentage (column b) by the promoter percentage to get encumbered shares as a share of the company: in the example, 10.00 per cent of 60.00 per cent is 6.00 per cent in Quarter 1, and 10.00 per cent of 58.82 per cent is 5.88 per cent in Quarter 2.
4. Read the diluted columns separately. If convertible securities outstanding changed, the diluted percentage can move while the basic percentage does not.
5. Check the category rows are like for like. A holder is shown in one category only, so a shareholder reclassified from public to promoter group, or the reverse, moves a whole holding between groups without a trade taking place.

Percentages are rounded in the filing, so differences of a few hundredths of a point can come from rounding alone.

Basis of these figures

Table structures, column headings, the (A+B+C2) percentage base, the encumbrance columns and the 2025 changes come from SEBI’s circular of 20 March 2025 (Annexure A). The filing deadlines come from Regulation 31(1) of the LODR Regulations as consolidated on SEBI’s website (amended up to 14 July 2026). The encumbrance description comes from Regulation 28(3) of the SEBI takeover regulations. The one-category rule, the nil-holding promoter group rule and the Regulation 31A reclassification point come from SEBI’s LODR FAQs. The numbers in the worked example are hypothetical and illustrate arithmetic only. Returns from any security are not guaranteed, and a shareholding pattern describes who held shares on a date, not what the shares will be worth.