Form PAS-6 is a crucial compliance requirement for companies that issue securities, especially unlisted public companies and certain private companies covered under Rule 9A and Rule 9B of the Companies (Prospectus & Allotment of Securities) Rules. As per MCA norms, the due date for filing PAS-6 for the half-year April to September is 29 November. Timely filing is essential to avoid penalties and ensure accurate reporting of share capital.
What is Form PAS-6?
Form PAS-6 is the Reconciliation of Share Capital Audit Report, filed half-yearly on the MCA portal. Its purpose is to match the company’s issued subscribed and paid-up capital with the number of shares held in dematerialized and physical form. It also verifies ISIN details, outstanding share certificates, and any changes in capital during the period. The form must be certified by a Practicing Company Secretary or Chartered Accountant.
References for Who Shall File PAS-6 (Legal Basis)
- Rule 9A(8) – Companies (Prospectus and Allotment of Securities) Rules, 2014
Mandates PAS-6 filing for unlisted public companies.
Reference: Every unlisted public company shall submit Form PAS-6 to the
Registrar with the details of reconciliation of share capital.
- Rule 9B – Companies (Prospectus and Allotment of Securities) Second Amendment Rules, 2023 (G.S.R. 802(E))
Applies PAS-6 filing to private companies other than small companies.
- MCA Notification dated 30 September 2019
Introduced mandatory half-yearly filing of Form PAS-6.
- Exemptions
- Based on Rule 9A, Rule 9B & MCA clarifications:
- Small companies
- Government companies
- Nidhi companies
- Wholly owned subsidiaries
The Significance of the 29 November Deadline
The MCA prescription requires compliance with the timeframes. If you miss the PAS-6 filing deadline of 29 November 2025, you risk penalties under Section 450 of the Companies Act. This means that companies might be liable for fines, higher daily penalties for continuing non-compliance and increased oversight by the ROC. Getting your reconciliation done in advance will ensure that you can get your certificate for filing without any last-minute rush and process delays.
Details Required for Filing PAS-6
- ISIN details for each class of securities
- Demat & physical shareholding data
- Changes in share capital such as bonus, rights, ESOPs, allotments and buy-back
- Details of pending dematerialisation requests
- Certification from a Practising CS/CA
Ensuring data accuracy is critical, as any mismatch between the company and depositories can delay filing.
How Complianceship Helps
At Complianceship, we provide complete assistance for PAS-6 filing—data preparation, share capital reconciliation, certification support and MCA submission. Our experts ensure your company files PAS-6 accurately and before the 29 November 2025 deadline, helping you stay fully compliant.
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