.svg){kind=icon}
Understanding the challenges of multiple closings in CCPS issuances
A common scenario in any company that has raised funds through CCPS is multiple closings i.e., same share class, identical terms but different allotment dates as investors come on board.
The standard practice was filing separate ISIN applications for each allotment date even though the securities were of the same share class. This meant multiple applications, different ISINs for identical securities, additional administrative work and documentation, complex record-keeping (and reconciliation) and extended timelines for processing multiple applications.
However, NSDL now accepts a single consolidated ISIN application for the allotted CCPS accommodating multiple allotment dates within one application, provided all other material terms such as conversion ratio, rights, preferences, maturity remain identical. (Note: If any of these conditions differ, then you will have to submit separate ISIN applications).
How a consolidated ISIN application works (with example)
A company issues 23,000 Series A CCPS on September 30, 2025 with 1% cumulative dividend, 1:1 conversion ratio, voting rights and maturity date of 2 years from the date of issuance of shares.
The allotment dates are as follows:
1st allotment: October 10, 2025: 10,000 shares (distinctive numbers: 1-10,000)
2nd allotment: October 15, 2025: 5,000 shares (distinctive numbers: 10,001-15,000)
3rd allotment: October 20, 2025: 8,000 shares (distinctive numbers: 15,001-23,000)
In the application form, the information will be structured as:
1. Distinctive numbers: Provide the range separately based on each allotment, not clubbed -
- First allotment: 1 to 10,000,
- Second allotment: 10,001 to 15,000, and
- Third allotment: 15,001 to 23,000
2. Date of allotment: Enter the date of the first allotment i.e. October 10, 2025
3. Remarks column: Provide complete details of all subsequent allotments -
- 2nd Allotment: October 15, 2025 - 5,000 shares, and
- 3rd Allotment: October 20, 2025 - 8,000 shares
4. Documents: Attach all relevant documents such as Board Resolutions, Form PAS-3, Payment Challans for all allotments and a clarification letter summarizing the consolidated allotments with relevant details for the reviewing officer's ease.
This approach of a single consolidated application means a cleaner cap table with one ISIN per class, less paperwork and faster processing of applications, simplified tracking and reconciliation.
Conclusion
When multiple closings are expected in a funding round, the most important step is to plan ahead. The terms can be structured identically for all tranches. This approach ensures that with a consolidated ISIN application filed, you can avoid last-minute restructuring or separate applications. Thoughtful coordination at the planning stage can save considerable time and reduce complexity later.
This streamlined approach reflects a practical understanding of early-stage and growth-stage funding dynamics. It's a meaningful step toward making the depository ecosystem more efficient and founder-friendly.
If you're working on a CCPS issuance spanning multiple closings; at EquityList we regularly guide startups through it and would be happy to help navigate the complexity. Get in touch with us here.
