Form PAS-6 Filing in India 2025: Applicability, Due Dates & ROC Compliance Guide

Form PAS-6 filing 2025 has become one of the most critical annual compliance requirements for unlisted public companies, mandated by the Ministry of Corporate Affairs (MCA). Introduced under the Companies (Prospectus and Allotment of Securities) Third Amendment Rules, 2018, this filing ensures transparency in share capital and helps the government monitor securities in dematerialized form. If your company is classified as an unlisted public company, understanding the PAS-6 compliance process is not optional — it's mandatory.

 


 

This guide will walk you through applicability, due dates, filing process, requirements, penalties, and everything that ensures error-free ROC compliance.

What is Form PAS-6?

Form PAS-6 is a half-yearly compliance form filed by unlisted public companies to reconcile the issued, subscribed, and paid-up share capital held in both physical and dematerialized (Demat) form. The form includes two mandatory attachments:

  1. Reconciliation of Share Capital Audit Report

  2. List of shareholders & share capital structure details

The report must be certified and digitally signed by a Practicing Company Secretary (PCS) or Chartered Accountant (CA). This filing helps MCA maintain a transparent record of share capital movement, prevent fraud, and maintain investor security.

Why Was PAS-6 Introduced?

The government introduced this form to:

  • Ensure monitoring of shareholding in demat format

  • Prevent fraudulent share issuance or transfers

  • Enhance corporate governance and investor trust

  • Bring unlisted public companies in sync with SEBI practices

  • Build a transparent securities audit trail through Depositories (NSDL/CDSL)

Thus, PAS-6 is more than a filing — it’s a compliance mechanism to keep Indian corporate share data systematic and reliable.

Which Companies Must File Form PAS-6 in 2025?

Form PAS-6 is applicable to:

All unlisted public companies (limited by shares)
 Companies that have issued shares in any form (physical or demat)

Who is NOT required to file?

 Private Limited Companies
 One Person Companies (OPC)
  Listed Companies (already governed by SEBI rules)
 Section 8 Companies (unlisted non-profit firms without share capital)

Important Note: Even companies with ZERO demat shareholders must still file PAS-6. The filing is not based on demat holdings, but on company type.

What is “Reconciliation of Share Capital Audit Report”?

The Reconciliation of Share Capital Audit Report is a mandatory audit document attached with Form PAS-6. It verifies:

  • Total issued, subscribed, and paid-up capital

  • Shares held in demat form (CDSL + NSDL)

  • Shares held in physical form

  • Any changes in share capital during the period

  • Reasons for discrepancies, if any

This audit ensures the company’s share data matches the depository records, maintaining alignment between corporate and regulatory information.

PAS-6 Due Date & Filing Frequency

Form PAS-6 must be filed twice each financial year, as it is a half-yearly compliance. The timelines are:

  • For April – September period → Filing due by 30th November

  • For October – March period → Filing due by 31st May

Companies must strictly track the PAS-6 due date, as missing deadlines can invite heavy penalties from the ROC.

Key Prerequisites Before Filing PAS-6

Before filing, ensure the following:

  1. Company ISIN (International Securities Identification Number) is activated

  2. The company is registered with a depository (NSDL or CDSL)

  3. Share capital records are updated

  4. Demat shareholder list is obtained from the depository

  5. Reconciliation of Share Capital Audit Report is certified and signed by a professional

  6. DSC (Digital Signature Certificate) of the authorized signatory is active

Step-By-Step Filing Process

  1. Generate ISIN – If not already activated, apply through a Depository Participant (DP)

  2. Connect with NSDL/CDSL – Ensure connectivity to update shareholder data

  3. Prepare audit report – Get the reconciliation report certified

  4. Draft Form PAS-6 – Fill in share capital details carefully

  5. Attach documents – Audit report, board resolution, shareholder data (if needed)

  6. Digitally sign the form

  7. Submit on MCA portal

  8. Pay prescribed challan fees

  9. Download acknowledgment

Common Mistakes Companies Must Avoid

Many businesses face resubmissions or notices due to errors such as:

 Mismatch between Demat and company records
 Incorrect CIN, ISIN, or share details
  Unsigned or invalid audit report
  Expired DSC of authorized signatory
 Skipping half-yearly intervals

Ensuring accuracy before submission prevents notices and penalties.

Penalties for Non-Compliance

The MCA has made it clear that non-filing or delayed filing of Form PAS-6 is a punishable offense under the Companies Act.

Typical consequences include:

  • Monetary penalties on the company and officers in default

  • Daily additional penalty for continued delay

  • Departmental scrutiny or notices

  • Impact on future corporate actions like fundraising, issue of securities, or company strike-offs

Thus, timely filing is strongly recommended to avoid regulatory complications.

How PAS-6 Supports Better Corporate Compliance

Strengthens Corporate Governance

Since shareholding data undergoes audit verification, internal controls improve.

 Ensures Dematerialization Compliance

The government is pushing toward 100% demat shareholding, and PAS-6 ensures companies adopt this move.

 Prevents Fraudulent Practices

Double verification between company books and depositories eliminates chances of fake or duplicate share issuance.

 Protects Investor Rights

Shareholders gain access to systematic, tamper-free records through regulated depositories.

Conclusion

Form PAS-6 is a crucial compliance for all unlisted public companies in India. It ensures transparency, validates share capital accuracy, and acts as a key governance tool in the evolving corporate ecosystem. Missing filings or submitting incorrect information can lead to notices, penalties, and operational hurdles. Hence, understanding the compliance cycle and sticking to reporting deadlines is essential.

To stay compliant in 2025, companies must maintain updated demat records, conduct timely reconciliation audits, and file within the prescribed timelines. Whether you're new to corporate compliance or managing recurring ROC obligations, filing PAS-6 correctly is non-negotiable.

Act on time, maintain accurate share records, and streamline your submissions to ensure seamless Form PAS-6 filing 2025. Visit https://compliancesarathi.in/ for more details.


Comments

Post a Comment

Popular posts from this blog

ROC Annual Filing Due Dates for FY 2024-25

Image
Timely ROC filing is a legal obligation for every registered company in India under the Companies Act, 2013. Whether you run a Private Limited Company, One Person Company (OPC), or a Limited Liability Partnership (LLP), you are required to comply with the Registrar of Companies (ROC) by filing essential statutory returns within specific deadlines. For the financial year 2024-25, it is crucial to stay updated with the  ROC filing due date FY 2024-25  to avoid penalties, notices, or even disqualification of directors. The Ministry of Corporate Affairs (MCA) mandates all companies to file their financial statements and annual returns every year. These filings allow the government to monitor corporate governance and ensure transparency. Missing these deadlines not only invites penalties but can also negatively impact your business credibility.  What is ROC Filing and Why It’s Important ROC filing refers to the annual submission of compliance documents by companie...
Read more

Trust Registration Process in India 2025 – Step-by-Step Guide

Image
  Starting a trust in India can be a rewarding way to serve society while ensuring transparency and legal recognition for charitable or religious activities. With updated laws and compliance requirements, understanding the   trust registration process in India 2025  is essential for NGOs, social workers, and individuals who wish to set up a charitable entity. This guide will explain the complete process, documents required, rules, and online application steps.  What is a Trust? A trust is a legal entity created by a settlor (founder) who entrusts property or assets to trustees for the benefit of beneficiaries or for charitable purposes. In India, trusts are mainly governed by: Indian Trusts Act, 1882  (for private trusts) State-specific Trust  Acts (pertaining to public religious or charitable trusts) Legal recognition, tax exemptions, donor trustworthiness, and adherence to laws are all guaranteed by registering a trust.  Types of Trusts in ...
Read more

ESI Scheme 2025: Eligibility, Medical Benefits, Salary Limit & How to Apply Online

Image
  The Employees' State Insurance (ESI) Scheme is one of India’s most important social security initiatives. It offers medical and financial support to employees during sickness, maternity, disability, or death due to employment injury. If you're wondering about  ESI scheme eligibility 2025 , salary limits, or how to apply online, this article is your complete guide. What is the ESI Scheme? The ESI Scheme is administered by the Employees’ State Insurance Corporation (ESIC), under the Ministry of Labour and Employment. Introduced in 1952, it aims to provide comprehensive social security benefits to employees earning below a certain wage threshold. This scheme is funded through contributions from both employers and employees and covers a wide range of medical and cash benefits.  ESI Scheme Eligibility 2025 Who is eligible in 2025? The  ESI scheme eligibility 2025  primarily depends on the employee's salary and the nature of employment. Here are the criter...
Read more