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Introduction and Its Compliance

Form PAS-6 is a half-yearly compliance report required to be filed by all unlisted public companies in India as per Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014. This report ensures that the share capital held in physical form is reconciled with the depository records, as mandated by the Ministry of Corporate Affairs (MCA). The form has to be certified by a Practicing Chartered Accountant or Company Secretary and need to be filed on half yearly basis for the half-year ending on the 31st day of March and the 30th day of September. Professionals Law supports in conducting the entire process of shareholder data collection, reconciliation with NSDL/CDSL data, preparation of form PAS-6, and its filing on MCA portal to enable accurate compliance with timeline for your unlisted public company.

Why It Is Needed

The MCA has made PAS-6 filing mandatory to promote transparency and dematerialisation among unlisted public companies. This helps prevent discrepancies in shareholding records and ensures that companies are progressively converting physical shareholding into electronic form. Filing PAS-6 also ensures compliance with the Companies (Prospectus and Allotment of Securities) Rules, thereby avoiding penalties and legal complications. Professionals Law guarantees your reconciliation will be done with precision and in accordance with depository protocol to keep your company in compliance and audit ready at all times.

Benefits and Advantages

Enhanced Transparency

Filing PAS-6 ensures proper reconciliation between physical and electronic shareholding, enhancing the accuracy of share capital records.

Regulatory Compliance

Helps companies fulfill MCA’s dematerialisation and filing mandates, avoiding legal non-compliance issues.

Improved Shareholder Trust

Builds confidence among shareholders by maintaining transparent and up-to-date records with depositories.

Penalty Avoidance

Timely filing of PAS-6 helps prevent MCA-imposed fines, prosecution or compliance notices.

Audit Preparedness

Maintains streamlined and verified records, aiding faster financial audits and regulatory reviews.

Eligibility Criteria

The following companies must file PAS-6:

  • All Unlisted Public Companies
  • Whose securities are held in dematerialised and/or physical form
  • Regardless of the number of shareholders
  • Applicable to both equity and preference shares

Note:

  • Private Limited Companies and Listed Companies are not required to file PAS-6.
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Documents Required

List of shareholders in both physical and demat form
ISIN (International Securities Identification Number) from NSDL/CDSL
Details of capital structure
Details of changes in shareholding, if any
Auditor/Practicing CA or CS certificate
Board Resolution authorizing the filing
Digital Signature Certificate (DSC) of authorized director
CIN and PAN of the company

Steps for Applying

1

Data Collection

Collect half-yearly shareholder data from company records and depositories.

2

Reconciliation Process

Match physical shares with electronic records using ISIN details.

3

Certificate Preparation

Obtain a certificate from a Practicing Chartered Accountant or Company Secretary.

4

Form Filing

Prepare and digitally sign Form PAS-6 on MCA portal with DSC.

5

Submission & Acknowledgment

File the form and retain SRN for future reference.

Frequently Asked Questions

Who needs to file Form PAS-6?
All unlisted public companies are required to file PAS-6.
Is PAS-6 required for private limited companies?
No, PAS-6 is not applicable to private limited companies.
What happens if PAS-6 is not filed?
Late or non-filing attracts a penalty of ₹10,000 and ₹1,000/day thereafter.
What if there is no change in shareholding?
Filing is still mandatory. You must report “No Change” if applicable.
What is the role of Professionals Law in PAS-6?
Professionals Law handles data collation, reconciliation, professional certification and MCA filing.
Do we need an auditor’s certificate?
Yes, PAS-6 must be certified by a practicing CA or CS.
Can we revise PAS-6 once submitted?
No, PAS-6 cannot be revised. Accuracy in the initial filing is essential.
Is PAS-6 applicable to preference shares?
Yes, both equity and preference shares must be reported in PAS-6.
How can Professionals Law help?
Professionals Law provides complete PAS-6 support—from document preparation to reconciliation, filing and post-filing assistance.

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