SEBI's revised block deal windows: Rs 25 crore minimum, 3% price range and the 2:05 PM VWAP-based afternoon window
SEBI's revised block deal framework: Rs 25 crore minimum order, 3% price range, 08:45 AM and 02:05 PM windows, VWAP-based afternoon pricing and same-day public disclosure.
Every trading day on Indian exchanges opens with a window most retail investors never see: the 15-minute block deal session that runs from 08:45 AM to 09:00 AM, before the regular cash market starts. Under SEBI circular SEBI/HO/MRD/POD-III/CIR/P/2025/134 dated October 08, 2025, titled "Review of Block Deal Framework", the rules for that window and its afternoon counterpart were rewritten. The minimum order size went up from Rs 10 crore to Rs 25 crore, the permitted price range widened from 1% to 3% on either side of the reference price, and the afternoon window moved to 02:05 PM to 02:20 PM with a volume-weighted average price (VWAP) as its anchor. This pre-open briefing sets out what the framework says, what changed from the old regime, and what to watch in today's session. The full circular is available on the SEBI circulars page.
A note on scope: the Oquilia Research Desk publishes only figures that are on the verified record for this briefing. This edition therefore does not quote Nifty 50, Sensex or sectoral index levels; it focuses on the block deal rules that govern how the largest single trades of the day are priced, sized and disclosed.
Market Snapshot
The October 08, 2025 circular modifies two earlier SEBI instruments: para 1.2 of Chapter 1 of the Master Circular for Stock Exchanges and Clearing Corporations (SEBI/HO/MRD-PoD2/CIR/P/2024/00181, dated December 30, 2024) and para 3.5 of the December 10, 2024 circular on the optional T+0 settlement cycle. According to the circular, the changes follow recommendations of a Working Group, deliberations in SEBI's Secondary Market Advisory Committee (SMAC) and public comments.
The table below is the one-glance snapshot of the framework as it applies to every session.
| Parameter | Morning window | Afternoon window |
|---|---|---|
| Timing | 08:45 AM to 09:00 AM | 02:05 PM to 02:20 PM |
| Reference price | Previous day's closing price | VWAP of cash-segment trades between 01:45 PM and 02:00 PM |
| VWAP dissemination | Not applicable | Exchanges compute and disseminate between 02:00 PM and 02:05 PM |
| Permitted order range | Within 3% either side of reference price | Within 3% either side of reference price |
| Minimum order size | Rs 25 crore | Rs 25 crore |
| Settlement | Compulsory delivery | Compulsory delivery |
Two structural points sit behind those 6 rows. First, the circular allows exchanges to set trading hours anywhere between 08:45 AM and 05:00 PM, with separate block deal windows inside that span. Second, every block trade must result in delivery; the circular rules out square-off or reversal of a block trade. That second rule is what separates a block deal from an ordinary large intraday order: a Rs 25 crore block is a genuine transfer of shares, not a position that can be closed out before 3:30 PM.
For readers new to the vocabulary, Oquilia's glossary entries on SEBI, liquidity and market capitalisation explain the building blocks used throughout this briefing.
What Moved Yesterday
The block deal framework did not change overnight; what "moved" is the set of thresholds that now governs every session compared with the regime that applied before the October 08, 2025 circular. The 4 changes below are the ones that alter how a block trade is executed.
| Rule | Earlier framework | Revised framework (Circular dated October 08, 2025) |
|---|---|---|
| Minimum order size | Rs 10 crore | Rs 25 crore |
| Price range around reference price | 1% either side | 3% either side |
| Afternoon window | Earlier timing under the 2024 Master Circular | 02:05 PM to 02:20 PM |
| Afternoon reference price | Earlier method under the 2024 Master Circular | VWAP of 01:45 PM to 02:00 PM cash-segment trades |
Minimum size: 2.5 times higher
Raising the floor from Rs 10 crore to Rs 25 crore is a 150% increase, or 2.5 times the earlier threshold. In share terms, the arithmetic is simple. Take a hypothetical stock with a reference price of Rs 1,000:
- Under the Rs 10 crore floor, the smallest permissible block was 1,00,000 shares.
- Under the Rs 25 crore floor, the smallest permissible block is 2,50,000 shares.
For a hypothetical stock priced at Rs 250, the floor works out to 10,00,000 shares. The effect is that the window is reserved for genuinely large transfers, typically between institutions, promoters and large funds.
Price range: from 1% to 3%
Widening the range from 1% to 3% on either side triples the room for negotiation around the reference price. On the same hypothetical Rs 1,000 reference price:
| Reference price | Old band (1%) | New band (3%) | Width of new band |
|---|---|---|---|
| Rs 1,000 | Rs 990 to Rs 1,010 | Rs 970 to Rs 1,030 | Rs 60 |
| Rs 500 | Rs 495 to Rs 505 | Rs 485 to Rs 515 | Rs 30 |
| Rs 2,000 | Rs 1,980 to Rs 2,020 | Rs 1,940 to Rs 2,060 | Rs 120 |
The circular states that the 3% range is subject to surveillance measures and the applicable price bands, so the wider range does not override a stock's normal circuit limits. A 3% discount on a Rs 25 crore block is Rs 75 lakh, compared with Rs 25 lakh at a 1% discount on the same notional value, which is why the wider range matters for sellers trying to clear large stakes in one print.
Afternoon anchor: VWAP instead of a single price
The afternoon window now uses a 15-minute VWAP, calculated on cash-segment trades between 01:45 PM and 02:00 PM, as its reference price. The exchanges compute this figure and disseminate it between 02:00 PM and 02:05 PM, and the window itself opens at 02:05 PM. A VWAP over 15 minutes of trading is harder to influence with a single print than a point-in-time price, which is the logic behind anchoring a Rs 25 crore-plus transaction to it.
What to Watch Today
Today's session follows the same timetable that applies on every trading day under the circular. The sequence below shows the checkpoints an investor tracking block activity should note.
| Time (IST) | Event | What it tells you |
|---|---|---|
| 08:45 AM to 09:00 AM | Morning block deal window | Large trades priced within 3% of the previous day's close |
| 01:45 PM to 02:00 PM | VWAP calculation period | Cash-segment trades that set the afternoon reference price |
| 02:00 PM to 02:05 PM | VWAP dissemination | Exchanges publish the afternoon reference price |
| 02:05 PM to 02:20 PM | Afternoon block deal window | Large trades priced within 3% of the VWAP |
| After market hours, same day | Public disclosure | Scrip, client name, quantity and price of each block trade |
1. Same-day disclosure after market hours
The circular requires exchanges to disclose block deal details to the public on the same day after market hours, including the scrip name, the client name, the quantity traded and the price. For retail investors this is the most useful output of the framework: a promoter selling 2% of a company or a mutual fund building a position through a block becomes visible by the evening of the trade date, not weeks later in a shareholding pattern.
2. The discount or premium to reference price
Because orders can now be placed up to 3% away from the reference price, the gap between a block print and the previous close (morning) or the 01:45 PM to 02:00 PM VWAP (afternoon) carries information. A block executed close to the 3% lower limit signals a seller willing to concede price; one executed near the upper limit suggests a buyer competing for stock. Neither is a forecast of where the stock will trade next, and the desk does not offer one.
3. Optional T+0 settlement
The circular also applies to the block deal window in the optional T+0 settlement cycle, amending para 3.5 of the December 10, 2024 T+0 circular. The same Rs 25 crore minimum, 3% range and compulsory delivery rules therefore carry across to block trades routed through T+0.
4. Normal-segment safeguards still apply
The circular states that trading, settlement, surveillance and risk-management measures applicable to the normal segment apply to block deals as well. A block window is a separate session, not a regulatory carve-out: margin, settlement and surveillance obligations continue to bind both sides of a Rs 25 crore-plus trade.
5. Effective date
The circular takes effect from the 60th day of its issue date of October 08, 2025. Exchanges and brokers were required to align their systems within that period, and the revised timings and thresholds now form part of the standard session structure.
What this means for a retail investor
A retail investor cannot place a Rs 25 crore order, so the block window is not a venue most individuals will use. Its relevance is indirect: block deals often reflect changes in promoter, institutional or fund holdings, and the same-day disclosure makes those changes public within hours. If you invest through mutual funds, your scheme may well be a counterparty in such trades; tools such as Oquilia's SIP calculator, lumpsum calculator and step-up SIP calculator help you model your own contributions over a 10-year or 20-year horizon, independent of the day-to-day price impact of any single block. For background on how fund units are priced and disclosed, the AMFI website publishes daily NAVs for every scheme.
FAQ
What is the minimum order size for a block deal under SEBI's revised framework?
The minimum order size is Rs 25 crore, raised from Rs 10 crore by SEBI circular SEBI/HO/MRD/POD-III/CIR/P/2025/134 dated October 08, 2025.
What are the block deal window timings?
The morning window runs from 08:45 AM to 09:00 AM and the afternoon window runs from 02:05 PM to 02:20 PM. Exchanges may set trading hours between 08:45 AM and 05:00 PM with separate block deal windows.
How is the reference price set for each window?
The morning window uses the previous day's closing price. The afternoon window uses the VWAP of cash-segment trades between 01:45 PM and 02:00 PM, which exchanges compute and disseminate between 02:00 PM and 02:05 PM.
How far from the reference price can a block deal order be placed?
Orders must be within 3% on either side of the reference price, up from 1% earlier. The range remains subject to surveillance measures and the stock's applicable price bands.
Can a block trade be squared off on the same day?
No. Every block trade must result in delivery, and the circular rules out square-off or reversal of block trades.
When and how are block deals disclosed to the public?
Exchanges disclose block deal details, including the scrip name, client name, quantity and price, to the public on the same day after market hours.
Does the revised framework apply to the T+0 settlement cycle?
Yes. The circular amends para 3.5 of SEBI's December 10, 2024 circular on optional T+0 settlement, so the revised rules apply to the block deal window in T+0 as well.