A COMPARATIVE STUDY ON INSIDER TRADING LAWS IN INDIA, UK, AND USA

Insider trading, the trading of securities based on unpublished price-sensitive information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.