Designated-person trading block on Zerodha (SEBI PIT trading window)
A designated-person trading block on Kite is a PAN-level freeze that stops an employee or insider of a listed company from trading in that company’s security while the company’s trading window is closed under the SEBI (Prohibition of Insider Trading) Regulations 2015 . The block is set by the listed company and applied through the depository, so Zerodha renders it but cannot lift it.
The exact message on Kite reads: “Trading is blocked in (instrument) for this session as you are a designated person of the company.” It is not a glitch and not a margin rejection. It is the visible end of a regulatory chain that runs from the SEBI PIT Regulations, through a company compliance officer who maintains a list of designated persons, to the depository that freezes the matching PANs against the company’s scrip for the closure window. This article covers what the message says, the precise regulatory cause, who counts as a designated person, the contra-trade and pre-clearance rules that sit alongside the window closure, and exactly how the block is lifted.
Conflict-of-interest disclosure. This guide is published by the WebNotes Editorial Team for informational purposes and is written independently. WebNotes operates a Zerodha account-opening referral programme, disclosed on the pages that carry the referral link; this guide does not carry it and earns no referral commission from the procedure described here.
What the message says
The block surfaces at order entry. You place a buy or sell order in a single specific scrip, the order is rejected before it reaches the exchange, and the rejection reason names you as a designated person of that company. The order never appears in the exchange order book because Zerodha’s risk management system stops it at the pre-trade validation layer, the same layer that handles RMS rejections and other order rejections on Kite .
Three properties of the message matter. It is security-specific: only the company where you are a designated person is frozen, every other instrument trades normally. It is bidirectional: it blocks both fresh buys and exits, so an open position in that scrip cannot be squared off while the window is shut. And it is account-anchored to your PAN, not to your Zerodha login, so the same freeze follows you across every broker and demat where that PAN is registered.
Why the block appears: SEBI PIT 2015 and the trading window
The rule sits in Schedule B, Clause 4 of the SEBI (Prohibition of Insider Trading) Regulations 2015, read with Regulation 9, which requires every listed company to frame a code of conduct that specifies a “trading window” and closes it for designated persons when they are reasonably expected to hold unpublished price-sensitive information (UPSI). The most common UPSI event is the company’s own financial results. For that event the regulation closes the window from the end of every quarter and keeps it shut until 48 hours after the results are declared to the exchanges.
Until 2022 the closure ran on an honour system: the compliance officer told designated persons not to trade, and breaches were caught after the fact. SEBI hardwired it with a circular dated 5 August 2022, which built a system to freeze the PAN of each designated person at the security level for the duration of the window. The company’s compliance officer uploads the list of designated persons and their PANs to the designated depository before each closure. The depository freezes those PANs against the company’s scrip across the market. When you place the order on Kite, the broker checks against that freeze and rejects the order, which is why the message names you specifically rather than citing a generic restriction.
SEBI widened the net with a circular dated 21 April 2025 that extended the automated PAN freeze to the immediate relatives of designated persons for results-related closures, applicable to every entity with equity or equity-convertible securities listed on a recognised exchange. Infrastructure investment trusts, real estate investment trusts and debt-listed entities are outside this automated mechanism. So a spouse, parent or child on the company list will see the identical block in that one security.
Who counts as a designated person
The PIT Regulations define designated persons by function, not by seniority alone. Regulation 9(4) requires the company board, in consultation with the compliance officer, to designate the persons covered. The standard set includes promoters and members of the promoter group, the chief executive and the directors, employees up to two levels below the chief executive, the chief financial officer and the finance team handling results, the company secretary and the compliance team, and any support staff, including IT and secretarial, who handle UPSI. Immediate relatives of all of these are pulled in for the automated freeze under the April 2025 circular.
The practical consequence for a Zerodha client is that the block does not depend on whether you actually hold UPSI on the day you trade. The freeze is categorical: if your PAN is on the list for that company, you cannot trade its scrip during the window, full stop. The regulation deliberately removes the case-by-case judgment, because proving who knew what on a given day is exactly the dispute the trading window is designed to avoid.
The numbers and rules around the block
| Item | Detail | Source |
|---|---|---|
| Exact Kite message | “Trading is blocked in (instrument) for this session as you are a designated person of the company” | Zerodha support, Kite error messages |
| Window closure for results | End of quarter to 48 hours after results declared | SEBI PIT 2015, Schedule B, Clause 4 |
| Enforcement | PAN-level freeze at the depository | SEBI circular dated 5 August 2022 |
| Extension to relatives | Automated freeze covers immediate relatives | SEBI circular dated 21 April 2025 |
| Contra-trade window | Six months between an opposite trade in the same security | SEBI PIT 2015, Schedule B, Clause 10 |
| Pre-clearance threshold | Above the value set in the company code (commonly Rs 10 lakh) | SEBI PIT 2015, Schedule B, Clause 5 |
| Exemption turnaround | Removed within 2 trading days of company instruction | SEBI circular dated 5 August 2022 |
These figures are set by regulation and the company code, not by the broker, so they hold across every broker, not only Zerodha.
Contra-trade and pre-clearance: the rules that flank the window
The trading window closure is one of three restrictions on a designated person, and the other two operate even when the window is open. The contra-trade rule in Schedule B, Clause 10 bars a designated person who has bought a security from selling it, or the reverse, within six months of the first trade. A breach is treated as a violation of the code, and any profit made on the contra-trade is liable to be disgorged and paid to SEBI’s Investor Protection and Education Fund. The rule exists to stop a designated person front-running near-term UPSI through quick round trips, even outside a formal window.
Pre-clearance is the second flanking rule. Schedule B, Clause 5 requires a designated person to obtain written pre-clearance from the compliance officer before trading above a value the company sets in its code, a threshold many companies fix at Rs 10 lakh. The pre-clearance lapses if the trade is not executed within the period the code allows, often seven trading days, after which a fresh clearance is needed. Neither contra-trade nor pre-clearance is enforced by the Kite order window, so a designated person carries personal responsibility for both even when no on-screen block appears.
How to clear the block
The block lifts on its own when the window reopens, so the first answer is to wait for 48 hours after the results are declared, the date that the company’s compliance officer sets and communicates. There is no broker action that speeds this up, because the freeze lives at the depository against your PAN.
Three steps are useful while the window is shut. First, exit other positions normally and use other instruments freely; only the one frozen scrip is restricted, and Zerodha permits an immediate-or-cancel order in any other instrument without limitation. Second, plan ahead: because the window also blocks exits, a designated person must square off any intraday or short-term position in the company scrip before the window closes, not during it. Third, if you believe you are wrongly on the list, or qualify for an exemption under Clause 4(3) of Schedule B read with Regulation 9, raise it with your company compliance officer, who can instruct the depository; an approved exemption is applied within two trading days. Note that mere cessation from the designated-persons list mid-window does not remove the freeze for that closure: if the company deletes your name because you have left the role, you stay frozen for the running window and become free only from the next one.
What this is not
This block is distinct from the other reasons an order fails on Kite, and confusing them wastes time. It is not a price-band rejection , which is about the limit price falling outside the day’s circuit limits . It is not an RMS rejection for margin or product restrictions. It is not a freeze-quantity cap on order size. The designated-person block names you personally as the reason and applies to one company’s security across your whole PAN, which no other Kite rejection does. If the message does not name you as a designated person, look to the other rejection causes instead.
See also
- Zerodha
- Kite by Zerodha
- Zerodha Console
- SEBI
- SEBI (Prohibition of Insider Trading) Regulations 2015
- SEBI Act 1992
- Trading window closure
- Insider trading rules for mutual funds
- SEBI rule on designated employees of mutual funds
- Why orders get rejected on Kite
- How to fix an RMS rejection on Zerodha
- How to fix a price-band rejection on Zerodha
- How to handle a freeze-quantity rejection on F&O
- Circuit limits and price bands
- National Stock Exchange
- Bombay Stock Exchange
- Open interest
- F&O trading
- Market order on Kite
- Limit order on Kite
- Stop-loss order
- Order validity types
- Trigger price versus limit price
- Why a market order is rejected on an F&O contract with no trades
- Order cannot be modified as it is being processed
External references
- Zerodha support: Trading is blocked for designated persons
- SEBI (Prohibition of Insider Trading) Regulations 2015
- SEBI circular on PAN-level trading window freeze, 5 August 2022
- SEBI circular extending automated trading window closure to immediate relatives, 21 April 2025
- SEBI: securities laws and regulations
References
- SEBI (Prohibition of Insider Trading) Regulations 2015, Regulation 9 and Schedule B, Clauses 4, 5 and 10 (trading window, pre-clearance, contra-trade).
- SEBI circular SEBI/HO/ISD/ISD/CIR/P/2022/107 dated 5 August 2022, automation of monitoring and implementation of trading-window closure by freezing the PAN of designated persons.
- SEBI circular SEBI/HO/ISD/ISD-PoD-2/P/CIR/2025/55 dated 21 April 2025, extending the automated trading window closure to immediate relatives of designated persons.
- Zerodha support, “Trading is blocked in (instrument) for this session as you are a designated person of the company” (as of 21 June 2026).
- SEBI Act 1992, Section 12A and Section 15G (prohibition of insider trading and penalty).