IR & AR WEEKLY ALERTS : ISSUE 104

Weekly IRO and Annual Report Intelligence

Regions: United Kingdom · India · United Arab Emirates (Dubai) · Qatar · Saudi Arabia
Date: Monday, 3 November 2025
Coverage window: 27 October 2025 to 3 November 2025

Why this matters

This week is about plumbing – the quiet systems that make disclosures and trading work. In India, the optional T+0 cycle remains in slow roll-out as brokers get more time to ready their systems. For issuers, that translates into practical drafting: acknowledge the phased adoption, potential liquidity/confirmation frictions, and how Treasury manages intraday cash and settlement risk. (Securities and Exchange Board of India)

In the UK, the FCA’s NSM changes switch on today, effectively rethreading the pipes your announcements run through. You’ll be asked for more exact metadata (including related-issuer LEIs), old labels are retired, and – usefully – there’s now a clean way to correct filings without making a mess. That means your submission checklists, headline code maps, and post-filing routines need updating now, not at year-end. (FCA)

And in Dubai, the DFSA has closed its Crypto Tokens consultation. Nothing to rewrite today, but if you have DIFC-regulated entities or crypto-adjacent pilots, keep a placeholder line in Risk/Controls so you can drop in the final wording without reopening the whole report. (dfsa.ae)

None of these are headline-grabbing policy shifts, but they touch the machinery that decides how cleanly you file, how your stock trades, and how you describe emerging risks. Tighten the SOPs now; future-you will thank you at 2 a.m. on results night!

United Kingdom Headlines

FCA implements NSM metadata changes; cutover outage completed (rules effective 3 November 2025).
Issuers must add the name and LEI of any related issuer to each disclosure; headline codes/categories are updated; “classification” is removed; and corrections to filings will be possible (prior versions retained but hidden from default view). The FCA flagged ESS/NSM unavailability from 18:30 UTC 31 Oct to 04:00 UTC 3 Nov for the transition. (FCA)
FCA PMB 58 – clerical corrections posted on 31 October (Update to prior coverage).
blackline errors in certain draft Procedural and Technical Notes and re-posted TN 602.5; consultation deadlines remain 21 November 2025 (most notes) and 5 December 2025 (specific notes). If you saved drafts before 31 Oct, re-download. (FCA)

Analysis (what changes for issuers)

NSM changes affect every UK regulatory filing you make via ESS/NSM from today: metadata completeness checks will now block submissions if related-issuer LEIs are missing; headline mapping in your internal trackers must be refreshed; and your disclosure manual should add a post-filing “correction” pathway. (FCA)
PMB 58 fixes do not change the policy direction but do change consultation pack references you might cite internally and in adviser instructions. (FCA)

IR actions this week

Update the Regulatory Disclosures SOP: insert fields for “Related Issuer Name” and LEI; refresh headline code picklists. (FCA)
Amend your NSM submission checklists to include a “correction” decision-tree and record-keeping for superseded versions. (FCA)
Circulate a cutover note to Legal/Comms noting the completed outage window and the live date. (FCA)
If you responded to PMB 58, replace any pre-31 Oct downloads with the corrected versions; align your internal citations to the 21 Nov / 5 Dec feedback dates. (FCA)

India Headlines

SEBI extends timeline for QSB systems/processes for optional T+0 settlement (circular dated 30 October 2025). Exchanges/NSDL have also circulated the extension reference. (Securities and Exchange Board of India)
SEBI: Implementation of eligibility criteria for derivatives on existing Non-Benchmark Indices (circular dated 30 October 2025). Aligns index-derivative eligibility on existing non-benchmark indices. (Securities and Exchange Board of India)

Analysis

The T+0 extension is broker-side but material for liquidity, settlement-risk and operational-dependency wording in MD&A/Risk. T+0 refers to optional same-day settlement in the cash equity segment – trades executed on the “T” day are paid for and delivered that same day (vs. T+1 next-day settlement) – which can tighten cut-offs, require pre-funding/early securities availability, and split liquidity between cycles. If your shareholder base is retail-heavy, disclose monitoring of settlement-cycle transitions and potential frictions during phased adoption. (Securities and Exchange Board of India). (Securities and Exchange Board of India)
Non-benchmark index derivatives eligibility may broaden hedging/volatility dynamics around constituent companies; “non-benchmark indices” are sectoral/thematic or custom indices outside the flagship benchmarks (e.g., not Nifty 50 or Sensex). SEBI’s framework sets quantitative tests – on constituent count and weights, liquidity/turnover thresholds, concentration caps, and market-cap coverage – that, once met, allow futures/options to be listed on those indices. This can expand hedging access, influence derivative-linked flows and basis/dispersion, so keep your Market Risk and Financial Instruments notes neutral but current. (Securities and Exchange Board of India)

IR actions this week

Insert a sentence in Risk → Market infrastructure/Settlement noting SEBI’s 30 Oct extension for T+0 optional cycle implementation by QSBs; add a cross-reference to Treasury’s liquidity management policy. (Securities and Exchange Board of India)
Ask your brokers’ corporate desk for a T+0 readiness statement and planned timeline; retain in your disclosure backfile. (NSE India)
For companies sitting in custom/non-benchmark indices, request an internal note on derivative-linked flows and whether any sensitivity tables need refresh. (Securities and Exchange Board of India)

United Arab Emirates (Dubai) Headline

DFSA CP168 (Crypto Tokens) – consultation closed on 31 October 2025; proposals include minor conduct requirement amendments reflecting market feedback. (dfsa.ae)

Analysis

If you have DIFC-regulated entities or crypto-adjacent activities (treasury pilots, tokenised instruments, wallet partnerships), start a gap-check on conduct, risk and disclosure language pending final DFSA text. (dfsa.ae)

IR actions this week

Flag an internal policy watch: assign Legal/Compliance to summarise CP168 implications and prepare draft risk/controls text variants for rapid insertion once finalised. (dfsa.ae)
Map any crypto-token exposure in cash management or innovation sandboxes to board-approved limits and disclosure thresholds. (dfsa.ae)

Qatar (Update)

No new issuer-wide rules/circulars posted within the window on QSE Market Notices; maintain existing governance and disclosure baselines. (qe.com.qa)

Saudi Arabia (Update / Watch)

CMA consultation on simplified investment funds remains in the pipeline (original call 06 Oct 2025). Keep on watch approaching November policy cadence. (cma.org.sa)

What to change in drafts already in circulation

India reporters

Risk → Market infrastructure & liquidity: Add: ~“SEBI extended the implementation timeline for optional T+0 settlement systems/processes for Qualified Stock Brokers on 30 October 2025; we continue to monitor settlement-cycle changes and potential impacts on liquidity and trade confirmations.” (SEBI). (Securities and Exchange Board of India)
Financial instruments note (if relevant): If your equity features in non-benchmark indices with active derivatives, acknowledge the 30 Oct SEBI criteria implementation and the team’s monitoring of derivative-linked flows. (SEBI). (Securities and Exchange Board of India)

UK reporters

Governance / Regulatory Disclosures page: Insert one line that, from 3 November 2025, NSM submissions include related issuer name and LEI and use updated headline codes; reflect that issuers can submit corrections (prior versions preserved on NSM). (FCA NSM). (FCA)
Project timetable footnotes: Note completed NSM cutover outage (31 Oct–3 Nov UTC) to explain any submission clustering or timestamp drift around the weekend. (FCA PMB 59). (FCA)
Prospectus/POATRs side-bar (if included): If you cite PMB 58 materials, refresh links and dates to the 31 Oct corrected drafts and 21 Nov / 5 Dec feedback deadlines. (FCA PMB 58). (FCA)

Dubai reporters (DFSA nexus)

Risk → Regulatory change: Pre-draft a neutral sentence on DFSA CP168 closure and pending outcomes that could tighten conduct controls for crypto-token activities. (DFSA). (dfsa.ae)

Watchlist & upcoming dates

3 Nov 2025 (today): FCA NSM metadata rules in force; ESS/NSM back from outage. (FCA)
21 Nov 2025: PMB 58 consultation feedback due (most notes). 5 Dec 2025 for specified notes (incl. TN 602.5 updates). (FCA)
On/around 24 Nov 2025: FCA to publish new PRM forms/checklists ahead of 1 Dec submissions under POATRs (for approvals on/after 19 Jan). (FCA)
6 Nov 2025: Saudi CMA – continue watching for next steps on “simplified investment funds” track. (cma.org.sa)

Sources (primary/official)

FCA: National Storage Mechanism changes page (ESS/NSM metadata & requirements) – (FCA)
FCA: PMB 59 (NSM outage timing and actions) – (FCA)
FCA: PS24/19 (NSM enhancements; in-force date) – (FCA)
FCA: PMB 58 (updated 31 Oct; consultation deadlines) – (FCA)
SEBI: Further extension for QSB systems/processes re T+0 (30 Oct 2025) – (Securities and Exchange Board of India)
NSE/NSDL circulars referencing SEBI’s T+0 extension – (NSE India)
SEBI: Implementation of eligibility criteria for derivatives on existing Non-Benchmark Indices (30 Oct 2025) – (Securities and Exchange Board of India)
DFSA: CP168 “Balancing Innovation and Investor Protection” (consultation closes 31 Oct 2025) – (dfsa.ae)
QSE: Market Notices (no new market-wide notices in window) – (qe.com.qa)
CMA Saudi: Announcements / public consultation index (context for funds track) – (cma.org.sa)