Service ID: V02-SVC-012 Direct Regulatory Service Rule 9A(8)

Form PAS-6 Share Capital Reconciliation Audit

Mandatory half-yearly audit report reconciling total issued share capital against shares held in dematerialized format (with NSDL and CDSL) and physical registers, preventing unauthorized share duplication.

Statutory Authority

Rule 9A(8) & Rule 9B, Companies (Prospectus and Allotment of Securities) Rules, 2014

Governing Jurisdiction

Republic of India (Central Portal)

Execution SLA

3 to 5 Business Days

Why This Statutory Filing Is Required

Mandatory half-yearly audit report reconciling total issued share capital against shares held in dematerialized format (with NSDL and CDSL) and physical registers, preventing unauthorized share duplication.

Statutory Mandate: Rule 9A(8) & Rule 9B, Companies (Prospectus and Allotment of Securities) Rules, 2014

Who This Service Is For & Statutory Eligibility

All unlisted public companies and all private companies other than small companies (paid-up capital > ₹4 Cr or turnover > ₹40 Cr).

Prerequisites & Mandatory Documents Checklist

  • International Securities Identification Numbers (ISIN) for all classes of equity and preference shares
  • Holding confirmation statements from National Securities Depository Limited (NSDL) and CDSL
  • Register of members showing physical vs dematerialized share breakups
  • Audit certification by a practicing Company Secretary or Chartered Accountant

Step-by-Step Portal Execution Procedure

  1. Step 1: Download demat capital statements from NSDL and CDSL as of half-year end
  2. Step 2: Reconcile demat holdings with physical share register and total issued share capital
  3. Step 3: Access Form PAS-6 web-form on MCA V3 within 60 days of half-year end (Due May 30 & Nov 29)
  4. Step 4: Input ISINs, share counts, transfer records, and attach reconciliation certificate
  5. Step 5: Affix Director Class 3 DSC and certifying PCS DSC; submit and pay fee via Bharatkosh

Transparent Pricing & Statutory Cost Architecture

Government Fees & Disbursements

Base ROC fee: ₹200 to ₹600 based on share capital.

Statutory Penalties for Non-Compliance

General penalty under Section 450 (₹10,000 + ₹1,000/day). Severe commercial ban: Under Rule 9B, private companies defaulting on dematerialization are **statutorily barred from issuing new securities, rights issues, bonus shares, or buybacks**, and shareholders cannot transfer shares.

Dedicated operational desk: Alappuzha, Kerala • Pan-India MCA V3 / Income Tax / GST e-Filing Infrastructure.

Frequently Asked Questions

What are the filing due dates for Form PAS-6?
Due May 30th (for October to March half-year) and November 29th (for April to September half-year).
Are small companies required to file Form PAS-6?
No. Small companies (capital ≤ ₹4 Cr & turnover ≤ ₹40 Cr) and government companies are fully exempt from mandatory dematerialization under Rule 9B.