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Governance August 19, 2026 2 min read

The error was survivable. The fifteen months were not.

CA Dhananjay Walke
CA Dhananjay Walke
Managing Partner, DRP & Co. LLP

The error was survivable. The fifteen months weren't.

Written on 19 August 2026, based on public reports at that time.

In March last year, a large listed private bank disclosed discrepancies in the accounting of its derivatives portfolio. Estimated impact, around 1,530 crore, about 2.35 percent of net worth. The stock fell 27 percent the next day. Painful, but survivable. Banks have absorbed worse. The capital was adequate, the franchise intact. Handled cleanly, this was an accounting correction with a bad quarter attached.

Then the regulator’s interim order reconstructed the timeline, and the accounting error stopped being the story.

Per the order, the chief executive had acknowledged the significant impact in an internal email fifteen months before the disclosure. Within days of that email, internal workings had pegged the hole at over 1,500 crore. Yet the information was formally classified as price-sensitive only six days before the market was told. And through that fifteen-month window, five senior executives, including the CEO and his deputy, sold shares, avoiding losses of nearly 20 crore, amounts the regulator has impounded while barring them from the market, prima facie, pending proceedings.

Here is the governance detail worth sitting with. Every listed company has two switches built for exactly this moment. The instant a potentially material problem surfaces internally, it gets classified as unpublished price-sensitive information, and the trading window shuts. Flip both, and executives cannot legally sell, the clock to disclosure starts running, and an error stays an error.

Here, neither switch flipped for fifteen months. The controls existed. Nobody pressed them.

That is the lesson for every board and audit committee. You do not only govern the size of a problem. You govern the clock on it. The question that belongs in every audit committee meeting is uncomfortable and simple. Is there anything we know that the market does not, and should.

Markets forgive errors. They price concealment. The disclosure you dread making is almost always cheapest today.

How does your board decide the day a problem becomes disclosable?

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Disclaimer: This article is prepared for general information purposes and should not be construed as professional advice. Views expressed are those of the author. Readers are advised to consult a qualified professional before acting on anything in this article. DRP & Co. LLP does not accept any liability for actions taken based on this article.