Published research · SSRN · 2026
An Architectural Gap in SEBI’s 2026 Framework and Its General Form
SEBI’s algorithmic trading framework closes the order chain but not the signal chain: a fully compliant order reaches the broker while what caused it remains invisible. This paper evidences that gap from primary regulatory sources across India, the EU, and the UAE, demonstrates that origin capture is feasible in production, and states the finding in general form for any framework that anchors accountability at an intermediary while the conduct of interest occurs upstream.
Published 14 July 2026· SSRN ID 7118421· Provisional patent filed 14 July 2026 — Application No. IN202621086466
What it argues
A broker’s order audit trail begins at the API call. Whatever produced the decision to make that call — a model, a group, a stranger on a messaging app — sits upstream of the first record anyone keeps. The order is traceable; its origin is not.
The paper establishes that this is structural rather than an oversight, shows the same shape in the EU and UAE frameworks, and demonstrates that capturing origin at the device is feasible in production rather than merely desirable. The general form applies to any regime that anchors accountability at an intermediary while the conduct of interest happens before it.
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