# Shareholding Pattern Analysis

> Read an Indian listed company's quarterly shareholding pattern for promoter behaviour, pledge risk, institutional flows and free-float dynamics. Use when the user asks who owns a company, whether promoters are selling, how much stock is pledged, whether FIIs or mutual funds are buying, or wants ownership tracked across quarters for an NSE/BSE-listed entity.

- Skill: `sharma23yash-oss/shareholding-pattern-analysis` (Agent Skill)
- Install (CLI): `npx skillmds@latest add sharma23yash-oss/shareholding-pattern-analysis`
- Raw SKILL.md: https://api.skillmd.com/api/skills/sharma23yash-oss/shareholding-pattern-analysis/raw
- Safety review: pending
- Works with: Claude Code, Claude.ai, OpenAI Codex
- Category: Coding & Dev Tools
- License: MIT
- Author: sharma23yash-oss (https://skillmd.com/u/sharma23yash-oss)
- Updated: 2026-09-17
- Page: https://skillmd.com/skills/sharma23yash-oss/shareholding-pattern-analysis

---


# Shareholding Pattern Analysis (India)

Filed quarterly under SEBI LODR Regulation 31, within 21 days of quarter end. It is the most under-read high-signal document in Indian markets: it shows what owners *did*, not what management *said*.

## The structure

| Category | What it contains |
|---|---|
| **(A) Promoter and Promoter Group** | Indian and foreign promoters, promoter-group bodies corporate, trusts |
| **(B) Public** | Institutions and non-institutions |
| — Institutions | Mutual funds, AIFs, banks, insurance companies, FPIs, NBFCs, pension funds |
| — Non-institutions | Individuals (split at ₹2 lakh nominal share capital), NBFCs, trusts, NRIs, bodies corporate |
| **(C) Non-Promoter Non-Public** | Shares held by employee trusts, ESOP trusts, depository receipts |

Plus mandatory annexures: shares pledged or otherwise encumbered, shares in dematerialised form, and a list of shareholders holding more than 1%.

## What to build

Track at least 8 quarters:

```
| Quarter | Promoter % | Pledge % of promoter | FPI % | MF % | Insurance % | Retail % | # of retail holders |
```

Derive:

```
Free float %          = 100 − promoter % − non-promoter non-public %
Free float market cap = market cap × free float %
Institutional %       = MF + FPI + insurance + banks + AIF + pension
Pledge (as % of total equity) = promoter % × pledge % of promoter holding
```

## The signals, ranked

### 1. Promoter stake change

- **Promoter selling into strength** while guiding for growth is the single most reliable negative signal in Indian mid-caps. Check whether the sale was disclosed as a bulk/block deal or crept down 0.3% at a time.
- **Creeping acquisition** — under SAST Regulations a promoter above 25% can acquire up to 5% per financial year without triggering an open offer. Steady buying inside that limit is a genuine positive.
- **A fall of exactly the pledge amount** usually means invocation, not a sale. Cross-check the encumbrance annexure and the Reg 31(1) pledge disclosure.
- Promoter % can also fall from dilution (QIP, preferential issue, ESOP exercise, conversion of warrants) without any promoter selling a share. **Always reconcile against share count, not just percentage.**

### 2. Pledge

```
Pledge % of promoter holding    Reading
0                               Clean
1–10%                           Monitor
10–25%                          Material; understand the borrowing
25–50%                          Structural risk; model an invocation scenario
>50%                            Treat the equity as an option on promoter solvency
```

A pledge increase in a falling market is a margin call in progress. Also look for "otherwise encumbered" — non-disposal undertakings and negative liens are disclosed separately and are economically similar.

### 3. Institutional flows

- **Mutual fund entry** is a quality filter: Indian AMCs run internal governance screens and take positions slowly. First-time MF entry into a small-cap is meaningful.
- **MF exit across multiple houses in one quarter** is a stronger signal than any single fund's move.
- **FPI %** — separate long-only from ETF/index flows. An index inclusion event (MSCI, FTSE, Nifty rebalancing) mechanically moves FPI % without any view being expressed.
- **Insurance company entry** (LIC in particular) is slow, valuation-sensitive money and rarely a momentum signal.

### 4. Retail behaviour

The number of individual shareholders holding up to ₹2 lakh nominal capital is disclosed. Read it as sentiment:

- Retail count exploding while institutions exit = distribution
- Retail count falling while MFs accumulate = accumulation
- Retail count is also the base for SEBI's minimum-public-shareholding and small-shareholder-director provisions

### 5. Structural constraints

- **Minimum public shareholding**: 25% for most listed companies. A promoter at 74–75% has no headroom to buy. A company below MPS is under a compliance clock and will dilute.
- **Free float and index eligibility**: index inclusion depends on free-float market cap. A promoter reducing stake can be preparing for index inclusion — a mechanical buyer.
- **Concentration**: the >1% shareholder list shows how few holders control the float. A thin float amplifies both directions and makes exit costly.

## Cross-checks

Pair every shareholding-pattern conclusion with:

- **Bulk and block deal data** from NSE/BSE for the quarter — names the counterparty
- **SAST disclosures** (Reg 29) for acquisitions crossing 5% and every subsequent 2%
- **PIT disclosures** (Reg 7) for insider trades above ₹10 lakh in a calendar quarter
- **AMFI monthly portfolio disclosures** for exact mutual fund positions, which are more granular and more current than the quarterly SHP

## Output format

```markdown
# <Company> — Ownership, <period>

## Trend
| Qtr | Promoter | Pledge (of prom.) | FPI | MF | Ins. | Retail | Retail holders |

## What changed and why
- Promoter: <Δ, and reconciled to share count>
- Pledge: <Δ and interpretation>
- Institutions: <who came in, who left — named where disclosed>

## Structural
- Free float: X% (₹Y cr)
- MPS headroom: ...
- Top holders >1%: ...

## Read
<2–4 sentences: what owners did, and whether it agrees with management's story>
```

## Hard rules

- **Reconcile percentages to absolute share counts** before calling anything a sale. Dilution moves percentages without trades.
- **Name the quarter and the filing date** for every figure.
- Do not infer intent. "Promoter holding fell 2.1% via a block deal on <date>" is a fact; "promoters are losing confidence" is not.
- Encumbrance disclosures cover pledges *and* other encumbrances — read both lines.

