A COMPARATIVE STUDY ON INSIDER TRADING LAWS IN INDIA, UK, AND USA
AUTHOR – GODHAWARI P* & DR. S.M. AZIZUNNISAA BEGUM**
* RESEARCH SCHOLAR, SCHOOL OF LAW, VISTAS, CHENNAI
** RESEARCH SUPERVISOR, SCHOOL OF LAW, VISTAS, CHENNAI.
BEST CITATION – GODHAWARI P & DR. S.M. AZIZUNNISAA BEGUM, A COMPARATIVE STUDY ON INSIDER TRADING LAWS IN INDIA, UK, AND USA, INDIAN JOURNAL OF LEGAL REVIEW (IJLR), 6 (9) OF 2026, PG. 901-907, APIS – 3920 – 0001 & ISSN – 2583-2344.
ABSTRACT
Insider trading, the trading of securities based on unpublished price-sensitive information (UPSI), poses a significant threat to market integrity, investor confidence, and the principle of fair disclosure. As financial markets become increasingly complex and interconnected, effective regulation of insider trading has become a global priority. This study provides a comparative analysis of the legal and regulatory frameworks governing insider trading in India, the United Kingdom, and the United States. It examines the relevant legislation, enforcement mechanisms, regulatory authorities, and penalties applicable in each jurisdiction. The study highlights the strengths and limitations of India’s SEBI (Prohibition of Insider Trading) Regulations, 2015, in comparison with the more established regulatory regimes of the UK and USA. By analysing international best practices, the paper identifies areas for reform and recommends measures to strengthen India’s insider trading framework. Effective regulation is essential for promoting transparency, protecting investors, and ensuring the stability and credibility of securities markets.