Long Post Alert:
๐ A big thank you to @yatinmota for taking up the concerns of retail investors directly with the SEBI Chairman during the recent press meet.
By raising the issue of genuine small-cap companies (under โน1000 Cr) being unfairly impacted by ESM rules, you gave voice to thousands of investors. ๐
๐ง Letโs unpack what this is all about โ the ESM framework, how it works, whatโs good, whatโs broken, and what needs to change:
๐ What is ESM (Enhanced Surveillance Measure)?
- Introduced by SEBI in June 2023 to curb manipulation in illiquid small-cap stocks (< โน500 Cr)
- Expanded in Oct 2024 to cover all stocks < โน1000 Cr including SMEs
- Aims to protect retail investors from volatility and speculative pumps
โ๏ธ How Does It Work?
๐ Stage I
๐นTrigger: Different price movement calculations and below 1000 crore.
๐น100% margin requirement
๐นT+2 implementation
๐นStock flagged as โunder surveillanceโ & Monitored for escalation to Stage II
๐ Stage II
๐นTriggered if stock rises 15% in 5 days or 30% in 1 month when in Stage 1
Stock is moved to Periodic Call Auction mode:
๐น 6 auction windows per day (1-hour each)
๐น 2% circuit filter
๐น No continuous trading
๐น Still 100% margin
๐ Minimum 90-day lock under ESM โ even if volatility reduces.
โ Intent is Good
Yes, speculative activity in small caps must be monitored.
Yes, retail needs protection from pump-and-dump operators.
But the current implementation is punishing growth and confidence โ not just speculation.
๐ It's also important to recognize that manipulations and governance issues are not limited to companies under โน1000 Cr market cap.
Even large and well-known companies have seen instances of wrongdoing.
So, applying stringent restrictions only to smaller companies may not be fair or effective from a market integrity standpoint.
๐จ Where Itโs Failing:
๐ธOnly Upward Movement Gets Flagged
๐ No action when stocks fall 50โ70% in lower circuits
๐ But a 15% or 30% rise? Straight to ESM 2 & Periodic Call Auction
โ ๏ธ Stocks can keep falling in ESM-1 โ without restrictions
๐ธPeriodic Call Auction Cripples Liquidity
HFTs game auctions, retailers panic seeing shallow order book.
Many donโt even know auction timings. Orders get trapped.
๐ธNo Price Discovery
Tight 2% band even on strong news or earnings = market inefficiency.
๐ธPerception of Guilt
Being in ESM = โriskyโ even if nothing is wrong fundamentally.
๐ธCompanies Struggle to Grow
Valuations get artificially suppressed, impacting fundraising and expansion.
๐ธFundamentals Are Ignored
EPS doubles, orders surge, and stock rises? Still punished.
๐ธStructural Advantage for High-Frequency Traders (HFTs)
Due to their direct exchange connectivity and faster infrastructure, HFT players often gain queue priority during time-sensitive Periodic Call Auction windows.
This edge has been seen even during SME listings with capped gains โ where early access translated into better execution and allocation compared to retail.
๐ธOrder Book Distortion During Auctions
Sophisticated participants use algos to place and cancel large orders right before auction close, making the order book look artificially strong or weak.
Retail investors react emotionally to these false signals, distorting true price discovery.
๐ Why do small-cap stocks move suddenly and sharply?
Because theyโre small.
A promoter often works tirelessly for months or even years to land a single large order, partnership, or tender.
And when they finally succeed โ the impact is immediate.
In many cases, the size of that one order is equal to the companyโs entire market cap.
So naturally, when that news is disclosed publicly, the market reacts.
Buying surges. The price moves.
๐งฐ These arenโt large companies doing steady business every day.
These are SMEs who grind for 30 days to land something big on the 31st โ and that breakthrough justifies a sudden re-rating.
But today, that success often triggers ESM restrictions โ penalizing both performance and ambition.
๐ Also, there's a clear disconnect we need to address:
On one side, the government is actively promoting MSMEs โ offering PLI schemes, awarding tenders, encouraging growth with lot of incentives for Make in India
But when an SME receives such an order and discloses it to the exchange, the stock often rallies โ only to be immediately flagged under ESM.
This traps the stock, freezes price movement, and prevents the promoter from raising funds at the right valuation โ funds that may be needed to execute the same government-backed project.
Isnโt that counterproductive?
๐ฌ As a retail investor, I fully support strong regulation.
We want SEBI to catch manipulation โ whether in stock price, books, or promoter behavior.
We want early warnings to avoid losing hard-earned money.
But that protection must come based on substance, not just price movement.
๐ Letโs not assume every price rise = manipulation.
These are small companies with small denominators.
Even a single order or contract can change the companyโs financials overnight.
When they grow 50โ100% YoY, the market wants to reward that growth โ and thatโs why we invest in small-caps in the first place: for the risk-reward.
๐ Yes, they can fail โ and thatโs fine.
๐ซ Whatโs not fine is Financial or Fundamental Wrong Doing. And that's where SEBI must act โ whether or not the stock is in ESM.
But the current framework:
โ ๏ฟฝ๏ฟฝ๏ฟฝPunishes genuine growth
โ ๏ธLabels every sharp rise as โsuspiciousโ
โ ๏ธDemotivates promoters who are finally seeing their years of work bear fruit
๐ก Suggestions for a Better Framework:
โ๏ธ Make ESM bi-directional.
Add tighter rules when stocks fall 30โ40% rapidly too โ not just for upside.
๐ Replace Periodic Call Auction with full-day trading.
Keep stocks open for regular trading under tighter 2โ5% bands.
Periodic Call Auction favors algos/HFTs and confuses retail participants.
๐ Keep all stocks in Trade to Trade.
This kills intraday speculation while maintaining liquidity.
๐ Ditch the 10โ20% band flexibility.
Stay with permanent 2% or 5% bands for consistency and discipline.
๐ Enable early exit if volatility stabilizes.
No point keeping fundamentally strong stocks locked for 90 days.
Donโt punish real growth. Blend price action with fundamentals like EPS, revenue growth, promoter holding, etc.
๐ฃ Transparent communication.
Announce clear reasons when a stock is flagged under ESM โ builds confidence.
If Periodic Call Auction is not removed then these suggestions are crucial as well:
๐งฒ Address HFT Advantage in Periodic Call Auction.
Introduce randomization or fair queueing to prevent HFTs from exploiting their infrastructure edge. Retail participants deserve equal access both for entry and exit.
๐ Prevent Order Book Manipulation in Auctions.
Impose limits on last-minute order cancellations and place strict checks to prevent artificial order book depth that misleads retail. (or)
โป๏ธ Adopt Pro-Rata or Lottery-Based Allocation in Periodic Call Auction.
Replace "first-come-first-serve" execution with lottery or pro-rata allocation at each price point. This levels the playing field and reduces bias toward faster systems used by institutional players.
โฒ๏ธ Randomize Auction Close Timings.
Similar to IPO listing time randomization, introduce randomized closing windows for each Periodic Call Auction session. This disrupts algorithmic timing tactics and preserves integrity of the price discovery process.
๐ In Summary:
We support surveillance โ but it must be smart, balanced, and fair.
Letโs catch wrong-doings and manipulators, not penalize genuine companies for growing.
Manipulations happen across market caps โ restricting only sub-โน1000 Cr stocks isnโt equitable.
Letโs build a framework that protects investors, rewards performance, and strengthens trust in our markets.
We, as investors, stand aligned with SEBIโs intent โ we only seek thoughtful execution.
Letโs stop financial wrongdoing โ and support Indiaโs next wave of growth stories. ๏ฟฝ๏ฟฝ๐
๐ Once again, thank you @yatinmota for asking the right question at the right time.
We hope SEBI acts with balance and clarity.
The investor community is watching โ and hopeful.
๐ Bondada Engineering Ltd informed the exchange that its consolidated operating revenue surpassed โน1,000 crore for the first time in a financial year, reaching โน1,049 crore as of January 31, 2025. #SME#BONDADA ๐๐๏ธ
๐ Bondada Engineering Ltd informed the exchange about receiving a โน2,28,17,57,713 Letter of Award from South Central Railways for ground infrastructure works under the Kavach Project. The scope includes provisioning of Kavach and 4G LTE-R high-density network and pile foundation for towers, to be executed within 720 days. #SME #BONDADA ๐๐๏ธ
๐ Bondada Engineering Ltd informed the exchange about receiving a โน108,90,02,500 work order from Bihar Renewable Energy Development Agency. The project involves the design, supply, installation, testing, commissioning, and maintenance of smart solar street light systems under the Mukhyamantri Gramin Solar Street Light Yojana in Bihar, to be executed within 18 months. #SME #BONDADA ๐กโ๏ธ
๐ Kore Digital Limited informed the exchange about a 511.35% YoY growth in total income for H1 FY25, reaching โน91.82 Cr. The company also highlighted a strong โน400 Cr project pipeline for FY25, including the Samruddhi and Mumbai Metro projects. #SME#KDL ๐ถ๐
Highlights:
- ๐ Total Income: โน91.82 Cr in H1 FY25, a 511.35% YoY growth compared to โน15.02 Cr in H1 FY24.
- ๐ EBITDA: โน10.88 Cr in H1 FY25, reflecting a 145.78% YoY increase from โน4.43 Cr in H1 FY24.
- ๐ฐ Net Profit: โน7.54 Cr in H1 FY25, a 142.44% YoY growth from โน3.11 Cr in H1 FY24.
- ๐ Diluted EPS: โน18.81 in H1 FY25, up 89.05% from โน9.95 in H1 FY24.
- ๐ง Project Pipeline: โน400 Cr worth of projects for FY25, including transformative initiatives like the Samruddhi and Mumbai Metro lines.
- ๐ Ongoing Work: Development and maintenance of 700+ KM Optical Fiber Cable Backbone across Mumbai and surrounding districts.
- ๐๏ธ Infrastructure Details: Over 600 pole-based cell sites, RTTs, GBTs, and Microwave backhaul installations.
- ๐ค Prestigious Clients: Serving Vodafone Idea Ltd, Bharti Airtel Limited, Reliance Jio, and Tata Teleservices.
- ๐ Market Presence: Entire revenue derived from Maharashtra, highlighting a focused regional strategy.
- ๐ Past Performance (FY24): Total income of โน105.08 Cr, EBITDA of โน17.08 Cr, and PAT of โน11.49 Cr.
- ๐๏ธ Licenses & Services: Licensed under Infrastructure Provider - I by the Department of Telecommunications, providing advanced communication solutions.
- ๐ ๏ธ Growth Strategy: Focus on transformative projects, expanding telecommunications infrastructure, and operational efficiency.
- ๐ฆ๏ธ Seasonal Impact: Monsoon season affected quarterly performance, with expectations of strong rebound in coming quarters.
๐ Rbm Infracon Limited informed the exchange about its approval for the financial results for the half year ended September 30, 2024. #SME#RBMINFRA ๐๐งพ
Crappiest rule on the planet
ESM Stage 2 with zero LOGIC
Examples from the list:
RBZ Jewellers
#RBZ
Was in esm 2 for the last 3 months
Stock fell from 270 to 130.. totally ok
Moved from 130 to 150
Was put to ESM Stage 2
Got out 10 days back
Moved 15% in 8 days
Back to ESM Stage 2 from tomorrow
AVP Infra
#AVPInfra
Stock declared extremely strong H1FY25 which was higher than H2FY24 as well
Naturally, stock was getting rerated
Hit 3 UCs
15%
Into ESM Stage 2 from tomorrow
TBI Corn
#TBICorn
Stock fell 40% from peak
Totally ok .no ESM
Stock had decent H1FY25
Moved 15%
Now into ESM stage 2 from tomorrow
Sathlokar Synergies
#SSEGL
#Sathlokar
Numbers tomorrow
Stock fell from 680 to 340..that's fine.. SMEs are meant to fall๐ฌ
Now stock moves up 15-18% from 350 to 412 in 10 days
Into ESM stage 2 from tomorrow
Totally senseless rule done by absolutely brainless, saddists who have no better job to do in life
ABSURD!!!
Defies all logic
๐ Kotyark Industries Ltd informed the exchange about the approval of Standalone and Consolidated Unaudited Financial Results for the half-year ended September 30, 2024, and an Interim Dividend of โน7.50 per equity share with face value โน10, setting the record date as November 15, 2024. Additionally, the company announced its decision to migrate to the Main Boards of NSE and BSE, subject to necessary approvals. #SME #KOTYARK ๐ฅ๐ฅ๐ผ
๐ RBM Infracon Ltd informed the exchange about receiving a service order valued at โน22,77,39,765.18 from thyssenkrupp Uhde India Pvt Ltd, for structural steel erection, mechanical, piping, and painting works at the Panipat Refinery. The order is scheduled for completion by December 31, 2025. #SME #RBMINFRA ๐๏ธ๐ ๏ธ
๐ Kotyark Industries Ltd informed the exchange about its upcoming Board Meeting on October 29, 2024, to consider and approve the unaudited financial results for the half year ending September 30, 2024, and discuss the proposal for payment of an interim dividend. Additionally, the Board will consider the migration of its listing from NSE Emerge to the Main Board. #SME #KOTYARK ๐๐
๐ Bondada Engineering Ltd informed the exchange about receiving a work order worth โน467,99,99,965 from KPI Green Energy Ltd. The order involves the supply of material and installation for a 130 MWp/100 MWac solar power generation plant, with execution over 12 months. #SME #BONDADA โก๐ง
๐ Kore Digital Limited informed the exchange about the release of their Investor Presentation for September 2024, which includes key financial highlights and strategic insights into their operations in telecommunications infrastructure development. #SME#KDL ๐๐
Highlights -๐
1. Strong Financial Growth: Revenue increased from โน4.49 Cr to โน50.77 Cr YoY. ๐
2. Robust Clientele: Serves major telecom players like Reliance Jio and Vodafone Idea. ๐ค
3. Infrastructure Expansion: Over 600 cell sites and 700 KM of optical fiber laid. ๐
4. Future Projects: โน400 Cr worth of projects planned for 2024-2025. ๐ง
5. Experienced Leadership: Management team with extensive industry experience. ๐งโ๐ผ
6. Market Position: Positioned as a key player in India's telecom infrastructure. ๐ฎ๐ณ
Key Insights -๐
1. Financial Performance Improvement -๐: KDL reported a remarkable increase in total income, reflecting strong operational performance and effective cost management strategies which position the company for sustainable growth.
2. Strategic Partnerships -๐ค: By collaborating with major telecom operators, KDL has secured significant contracts, enhancing its market presence and establishing trust within the industry, crucial for future expansions.
3. Infrastructure Development -๐: The extensive deployment of cell sites and fiber optics showcases KDLโs commitment to enhancing telecommunications infrastructure, effectively meeting the growing demand for high-speed connectivity.
4. Future Growth Pipeline -๐ง: With โน400 Cr projects in the pipeline, KDL is poised for substantial revenue growth, indicating a proactive approach to capitalize on emerging market opportunities.
5. Management Expertise -๐งโ๐ผ: The leadership teamโs diverse experience is pivotal in navigating industry challenges, ensuring strategic goals align with market trends and technological advancements.
6. Market Demand Trends -๐ฎ๐ณ: As the Indian telecom market expands, KDL is strategically positioned to leverage opportunities arising from increased internet penetration and demand for next-gen technology.
@nileshkurhade@Nithin0dha@zerodha Totally agree with you Nilesh. @Nithin0dha@zerodha What do you think you are doing by putting 3% limits for SME stocks? Did you know that SME stocks can easily move from LC to UC and vice versa? (These circuit limits range from 5-20%, in case u didn't know)
๐ RBM Infracon Limited informed the exchange about receiving a contract order worth โน13,105,850 from Reliance Industries Limited. The contract involves UG piping fabrication and laying, including associated civil work for Train-1 (5 GW) at Reliance's PV Manufacturing Complex in Jamnagar. #SME #RBMINFRA ๐๏ธ๐
๐ Exhicon Events Media Solutions Ltd informed the exchange about a scheduled virtual meeting with Tiger Assets on September 15, 2024, at 11:00 AM. #SME#EXHICON ๐ฅ๏ธ๐ผ