SEBI by way of its Circular dated September 08, 2017, had categorised registrars and transfer agents (‘RTA’) that service more than two crore (20 million) folios as a Qualified RTA (‘QRTA’). In this regard, SEBI by way of Circular dated March 10, 2023 (‘Circular’), has clarified that an RTA will be categorized as a Qualified RTA, for the next three financial years, if at any time in a financial year, the combined number of physical and demat folios being serviced by the RTA for listed companies exceeds two crores (20 million) and this status will not change irrespective of any subsequent fall in folios. Further, the Circular requires RTAs that exceed this threshold to: (i) intimate SEBI within five working days; and (ii) implement enhanced requirements mandated for QRTAs within 60 days thereof.