Form PAS-6 Filing in India: Applicability, Form Details, and Deadlines
Form PAS-6 is a Reconciliation of Share Capital Audit Report that unlisted public and private companies must file every half year. The form is submitted to the Registrar of Companies (ROC) via the MCA portal.
PAS-6 ensures shares of unlisted public and certain private companies are dematerialized. It also enforces compliance with the Companies Act and related rules.
By making PAS-6 filing mandatory, the Ministry of Corporate Affairs (MCA) aims to improve transparency. It reduces the risk of fraud and aligns governance standards of unlisted entities with those of listed ones.
In this blog, we will cover PAS-6 applicability, the details required in the form, and the filing due dates under company law.
Legal Background of PAS-6: Rules, Compliance, and MCA Guidelines
Form PAS-6 was introduced under Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014, through an amendment in 2019. It requires unlisted public companies to issue and maintain securities only in dematerialized form.
This requirement was formally introduced by the Ministry of Corporate Affairs (MCA) through a notification on September 10, 2018, under Rule 9A (8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. This step aimed to improve transparency, prevent fraud, and align unlisted company compliance with listed entities in India.
| Form PAS-6 plays a key role in ensuring transparency and corporate governance for companies. To understand how these requirements differ across company types, explore our detailed guide on types of companies in Company Law. |
Key Requirements under Rule 9A for PAS-6
Rule 9A(11) mandates a half-yearly reconciliation of share capital, to be filed in Form PAS-6 and certified by a practicing Company Secretary or Chartered Accountant.
| Requirement | Description |
| Issue of Securities | All new securities must be issued only in dematerialized form |
| Existing Securities | Companies must facilitate the dematerialization of all existing securities as per the Depositories Act, 1996 |
| Applicability | Applies to all unlisted public companies |
Dematerialisation Before Certain Actions
Before carrying out the following activities, companies must ensure that all directors, promoters, and key managerial personnel (KMPs) have dematerialized their holdings:
| Activity | Condition |
| Issue of new securities | Allowed only after dematerialisation |
| Buyback of securities | All relevant holdings must be in demat form |
| Issue of bonus shares | Allowed only if holdings are dematerialised |
| Rights offer | Permitted after dematerialisation of existing holdings |
Obligations for Security Holders
| Situation | Requirement |
| Transfer of securities after 2 Oct 2018 | Securities must be dematerialized before transfer. |
| Subscription to new securities after 2 Oct 2018 | All existing holdings must be in demat form before subscribing. |
Additional Requirements for Companies
- Apply to a recognized depository under the Depositories Act, 1996.
- Obtain an International Security Identification Number (ISIN) for each security type.
- Inform all existing security holders about the dematerialization process.
PAS-6 Applicability: Who Must File Form PAS-6
Form PAS-6 is a half-yearly return for unlisted companies that must maintain their securities in demat form. After the 2023 insertion of Rule 9B, this requirement also covers certain private companies that exceed the seed capital threshold and issue or transfer shares.
| Applicable To | Not Applicable To |
| All unlisted public companies in India | Small private companies |
| Private companies, except small companies | Unlisted Nidhi companies |
| Section 8 companies with share capital | Wholly owned subsidiaries of unlisted public companies |
| Wholly owned subsidiaries of private companies | Government companies |
In short, PAS-6 applicability extends to most unlisted entities that issue or hold share capital, except those specifically exempted by law.
To understand more about wholly owned subsidiaries and their features under company law, read our detailed guide here: Wholly Owned Subsidiary: Features and Functions
PAS-6 Form Details: Documents and Information Required for Filing
Form PAS-6 collects essential information about a company’s share capital. Key details include:
- Issued and Dematerialized Share Capital – Reports the total number of shares issued and those held in dematerialised form
- ISIN and CIN – Captures the International Securities Identification Number and Corporate Identification Number
- Shareholding of Directors and Promoters – Lists total shares held by directors, promoters, and KMP
- Demat Requests – Tracks pending and confirmed demat requests beyond 21 days
- Capital Structure Changes – Records changes such as bonus issues, rights issues, buybacks, or conversions
- Reconciliation Certificate – Certification by a Practicing CA or CS confirming reconciliation
PAS-6 Due Date: When to File Form PAS-6
Form PAS-6 must be filed within 60 days after the end of each half-year. Key deadlines are:
- 30 May – For the October to March period
- 29 November – For the April to September period
Filing on time ensures compliance and avoids penalties.
Step-by-Step PAS-6 Filing Process in India
- Log in to the MCA Portal – Open the MCA website and sign in.
- Download the PAS-6 Form – Go to “Company Forms” and download the e-form.
- Fill Company Details – Enter CIN, ISIN, and share capital information.
- Add Digital Signature – Attach the DSC of the director, CEO, CFO, or company secretary.
- Get Certification – Have a practicing CA or CS certify the form.
- Submit the Form – Upload the completed form and pay the filing fees.
- Save Acknowledgement – Note the SRN and download the acknowledgement for records.
| To ensure compliance, every company must also maintain a valid Corporate Identification Number (CIN) issued by the MCA. Learn more about its structure and importance here: CIN Number – What It Is, Structure, Importance & How to Check. |
Penalties for Missing PAS-6 Filing
Failing to file PAS-6 on time attracts monetary penalties under the Companies Act.
| Type of PAS-6 Penalty | Amount |
| Initial Delay | ₹10,000 for late filing of PAS-6 |
| Continued Delay | ₹1,000 per day if the default continues |
| Maximum Penalty for Company | ₹2,00,000 in total |
| Maximum Penalty for Officer | ₹50,000 per defaulting officer |
Filing on time helps you avoid these penalties and stay compliant. The penalty applies separately to the company and each responsible officer, and it continues to accrue until the filing is completed.
Importance of PAS-6 Filing
Filing PAS-6 is crucial for maintaining transparency and compliance in unlisted companies. Key benefits include:
- Ensures Accurate Share Data – Keeps records of issued and dematerialised shares correct.
- Aligns with Listed Company Standards – Brings unlisted companies’ practices in line with regulatory norms.
- Prevents Fraud – Reduces risk of shareholding discrepancies and misuse.
- Strengthens Corporate Compliance – Helps companies stay compliant with MCA regulations.
Conclusion: Ensure Compliance with Timely PAS-6 Filing
Timely filing of Form PAS-6 is not just a legal requirement. It protects your company from heavy penalties and regulatory scrutiny.
Thus, accurate demat records are essential. They form the backbone of shareholder transparency and audit compliance. LegalWiz.in simplifies the process of filing PAS-6. We guide you step by step to ensure filings are precise, timely, and fully compliant. This lets you focus on growing your business without compliance worries.
Frequently Asked Questions
What is Form PAS-6?
Form PAS-6 is an electronic form that is required by law. You utilize it to send the Reconciliation of Share Capital Audit Report to the Registrar of Companies (ROC). The form ensures that a company’s records reflect the amount of capital it has issued, subscribed, and paid up.
Who needs to file Form PAS-6?
Form PAS-6 must be filed by all unlisted public companies and private companies notified under Rule 9A and 9B, except Nidhi, government companies, and wholly owned subsidiaries. Non-small private companies with mandatory demat requirements must file after obtaining their ISIN. The filing must be completed within 60 days of each half-year’s end.
When is the last day to file Form PAS-6?
Form PAS-6 must be filed within 60 days after the end of each half-year, with the key deadlines being 30 May for the October to March period and 29 November for the April to September period. Late filing attracts penalties as per Section 450 of the Companies Act, 2013.
What are the penalties for non-compliance with PAS-6?
If the corporation and its officials don’t submit Form PAS-6 on time, they might face fines. Up until the form is filed, these penalties might add up every day.
Can Form PAS-6 be filed online?
Yes, you may send in Form PAS-6 online using the MCA site. You must provide digital signatures from the directors, the company secretary, or other authorized people.
Sapna Mane
Sapna Mane is a skilled content writer at LegalWiz.in with years of cross-industry experience and a flair for turning legal, tax, and compliance chaos into clear, scroll-stopping content. She makes sense of India’s ever-changing rules—so you don’t have to Google everything twice.
