FORM PAS-6: Share Capital Audit Report Reconciliation

FORM PAS-6 Reconciliation

Introduction of E-form PAS-6

Reconciliations! The Ministry of Corporate Affairs(MCA) through General Circular G.S.R. 376(E). dated 22nd May 2019 has introduced “Reconciliation of Share Capital Audit Report (Half-yearly)” as per sub-rule 9A (8) of Companies (Prospectus and Allotment of Securities) Rules, 2014 and has issued Companies (Prospectus and Allotment of Securities) Third Amendment Rules, 2014 and has provided Companies (Prospectus and Allotment of Securities) Third Amendment Rules, 2019 which shall be effective from 30th September 2019.

Key Features of E-form PAS-6

  1. Every public company that is unlisted and that comes within the purview of this rule shall comply with the submission of “E-form PAS-6” to the registrar of companies with the fees as mentioned in Companies (Registration Offices and Fees) Rules, 2014 in no more than 60 days that shall start from the conclusion of each half-year.
  2. “E-form PAS-6” can only be certified by a practicing chartered accountant or practicing company secretary.
  3. For each ISIN individually, all the necessary information is required to be submitted half-yearly (2 times in a year)in every financial year for periods ending 31 March and 30th September.
  4. However, due to the prevailing CORONA Pandemic, companies have faced trouble while sending notices through postal or courier services.
  5. The above-mentioned rules and regulation are not applicable in the case of:
    • A Nidhi
    • A wholly-owned subsidiary and
    • A Government Company

Key Takeaways

Following Information and details are required while submitting “E-form PAS-6” :

    1. Corporate Identification Number(CIN) is required.
    2. International Securities Identification Number (ISIN).
    3. Following particulars of the company are required:
      • Issued Share Capital along with the number of shares is required.
      • Total number of shares that are held in both dematerialised form and physical form
    4. Mention details of changes in share capital during the above-mentioned half years
    5. Details of shares held by the following three stakeholders: Promoters, Directors and Key Managerial Personnel (KMPs).
    6. Total number of Demat requests.
    7. Details of Company Secretary if any.
    8. Details of CA/CS certifying “E-form PAS-6”.

    However, attachments to the “E-form PAS-6” are not required.

    Prerequisites for filing MCA’s “E-form PAS-6”

    1. Enter the number and that date which authorises the signatory to sign.
    2. To ensure that the Electronic-form has been digitally signed by the Manager, Director, CEO, Company Secretary or CFO.
    3. The person should have already registered his Digital Signature Certificate (DSC) with MCA.
    4. Any director who has been disqualified is not required to sign the form.
    5. If a person who is signing digitally is a company secretary, enter a membership number that is valid in case of other than section 8 of the company. However, in the case of section 8 company and company secretary, either membership number or PAN details should be mentioned.

    Processing Mode

    The form shall be processed in Spanning Tree Protocol (STP).

Availability of Form

“E-form PAS-6” has been accessible for filing as Electronic-Form w.e.f 15th July 2020.

Due date: 13th September 2020 as per Circular

As per the general circular of MCA bearing number 16/2019 and dated 28th November, 2019, the deadline for filing Form PAS-6 due date without paying additional fees for the half-year ending on 30th September 2019 shall be 60 days from the date of uploading of this form on the website of MCA.

Period of Reporting

Half-year ending 31.03.2020

MCA has issued last General Circular bearing number 16/2019 on
28th November 2019 associated with the period of reporting i.e. half year ending 30.09.2020.

The deadline for filing “E-form PAS-6” without additional fees for the half-year ending on 30.09.2019 shall be sixty days from the date of uploading of this form on the website of MCA.

It means that after the availability of the MCA-“E-form PAS-6”, the period of reporting shall be:

a). Half-year ending on 30.09.2019
b). Half-year ending on 31.03.2020

However, practically the aforesaid form is not taking effect for the half-year ending 30.09.2019. Consequently, filing of form for the first time shall be done for half-year ending on 31.03.2020.

Can the MCA’s “ E- form PAS-6” be filled after the lapse of 60 days at present without additional fees/penalty?

Point No. 1 of MCA’s general circular bearing number 11/2020,
F No.2/1/2020-CL-V dated 24.03.2020 while considering the situation of COVID-19 outbreak clearly stated that:

No late fee shall be charged for the late filing during a moratorium period from April 1 to September 30th 2020 with respect to any document, return, statement etc. that is required to be filed in the MCA’s-21 Registry.

Considering the above-mentioned information, we can say that MCA’s
“E-form PAS-6” can be filed after 13th September 2020 i.e. after 60 days of deployment till 30th September 2020 during a moratorium period.

Draft Certificate by practicing professional I declare that I – (PCS / PCA) have been duly engaged for the purpose of certification of this form.

It is hereby certified that I have gone through the provisions of the Companies Act, 2013, the Depositories Act, 1996, and rules/regulations made thereunder for the subject matter of this form and matters incidental thereto and I have verified the above particulars (including attachment(s)) from the original records maintained by the

Company (name of the company) which is the subject matter of this form and found them to be true, correct and complete and no information material to this form has been suppressed.

I further certify that: a) The said records have been properly prepared, signed by the required officers of the Company and maintained as per the relevant provisions of the Companies Act, 2013 and the Depositories Act, 1996 and were found to be in order; b) All the required attachments have been completely and legibly attached*to this form; c).

It is understood that I shall be liable for action under Section 448 of the Companies Act, 2013 for the wrong certification if any found at any stage.

Chartered Accountant in Practice /Company Secretary in practice
(whether Associate or Fellow)
Membership No. & CP No.

Note: The above-mentioned e-form has been taken on the basis of the file that is maintained by the Registrar of Companies via electronic mode on the basis of a statement of correctness that is given by the filing company. Also, Attention is being drawn to the provisions of section 448 which provides for the punishment for furnishing false statements and certification.

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All you need to know about Form PAS-6 is a ‘Reconciliation of Share Capital Audit Report’ which needs to be submitted on a half-yearly basis. However in some cases if you want to find out view more details of the e-form pas-6? if yes then here we also provide one of the best details of this article post.

Let’s follow more information regarding the reconciliation of the Share Capital Audit Report’ which needs to be submitted on a half-yearly basis.


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