Framework for Intraday Position Limits Monitoring for Equity Index Derivatives
Summary
SEBI establishes an entity-level intraday monitoring framework for index options to address risks from outsized positions on expiry days. The circular sets specific Net and Gross Future Equivalent (FutEq) limits of ₹5,000 crores and ₹10,000 crores respectively, monitored via random snapshots by Stock Exchanges. Implementation begins on October 1, 2025, with penalty provisions for expiry day breaches effective from December 6, 2025.
Text
Intraday Net position limit (FutEq basis) for each entity shall be ₹5,000 cr. (as against end of day limit of ₹1,500 cr).
Intraday Gross position limit (FutEq basis) for each entity shall be ₹10,000 cr. (i.e. separately both on long and short sides), same as the present end of day limit.
The aforesaid intraday limits shall continue to be monitored by Stock Exchanges through a minimum of four random snapshots during the trading day (including one snapshot between 14:45 hrs to 15:30 hrs i.e. around market closing time where heightened activity is geberally observed).
Further, in order to monitor the intraday positions of entities, as mentioned aforesaid, the Stock Exchanges shall consider the underlying price at the time of taking positions snapshots.
Entities shall be allowed to take additional exposure against holding of securities or cash/cash equivalent, as applicable, in line with para 5.5.3 of SEBI circular dated May 29, 2025.
For the entities breaching the aforesaid limits, Stock Exchanges shall examine trading patterns of such entities which would inter-alia include seeking rationale for such positions from the clients, examining trading in the constituents of the index by the entity and discussing such instances with SEBI in the surveillance meeting.
On the day of expiry of options contracts, the breaches of aforesaid position limits shall additionally attract penalty/additional surveillance deposit, as decided jointly by Stock Exchanges.
The aforesaid framework would facilitate market making activity on all trading days while putting a check on creation of outsized intraday position on the expiry day for orderly trading.
The aforesaid framework would also provide predictability, operational clarity, and a fair balance between ease of trading and risk management.
The aforesaid framework shall be restricted to index options only.
Stock Exchanges and Clearing Corporations are advised to prepare a joint Standard Operating Procedure (SOP) detailing modalities for intraday monitoring in line with the instant circular and submit the same to SEBI within 15 days from the date of this circular and issue an SOP to market participants before the Circular becomes effective.
The provisions of the Circular shall come into effect from October 01, 2025 except for the provision mentioned at para 4.7 above which shall come into effect from December 6, 2025 (i.e. at the end of glide path of FutEq based positions limits, as mentioned at Para 2 above).
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Source: SecMarx — Framework for Intraday Position Limits Monitoring for Equity Index Derivatives. Verbatim text is public record; SecMarx structuring (linkage to applying orders) is cited to us.