Form CHG-9: Complete Guide to Registration of Creation or Modification of Charge for Debentures on MCA Portal
What is Form CHG-9?
Form CHG-9 is the web form filed by a company with the concerned Registrar of Companies (RoC) for registration of creation or modification of charge for debentures, or rectification of particulars filed in respect of creation or modification of charge for debentures. It is governed by Sections 71(3), 77, 78, and 79 of the Companies Act, 2013 and Rule 3 of the Companies (Registration of Charges) Rules, 2014.
Key Distinction from CHG-1: CHG-9 covers charges specifically related to debentures, while CHG-1 covers all other charges. If a company issues debentures secured by a charge on its assets, that charge must be registered using CHG-9.
For Foreign Companies: The concerned ROC is always the Delhi ROC.
When is CHG-9 Filed?
CHG-9 is filed for:
- Creation of a new charge — when debentures are issued with a charge created on company assets as security
- Modification of an existing charge — when the terms of a registered debenture charge are altered
- Rectification of charge particulars — when an omission or misstatement is found in a previously filed CHG-9 (or old Form 10 / CHG-8) and needs to be corrected
Important Checkpoints Before Filing
- Register as a Business User on MCA portal before filing
- Company must have a valid and approved CIN or FCRN
- DSC must be registered on MCA portal against the correct DIN/PAN/Membership number
- Authorised signatories must have an approved DIN, valid PAN, or valid membership number
- DSC must be valid, non-expired, and non-revoked
- For rectification: approved SRN of the relevant CHG-9 / old Form 10 / CHG-8 must be available
- For resubmission: T+15 days from ‘Resubmission Required’ marking must not have elapsed
Step-by-Step Filing Process
Option 1: Via MCA Services Menu
- Login to MCA portal
- Go to MCA Services → E-Filing → Company Forms Download
- Navigate to “Charge related filings”
- Access “Application for registration of creation or modification of charge for debentures or rectification of particulars filed in respect of creation or modification of charge for debentures (Form CHG-9)”
- Enter Company Information
- Fill up the application
- Optionally save as draft (enabled after entering CIN)
- Submit the webform
- Note the SRN generated
- Affix DSC on the generated PDF
- Upload DSC-affixed PDF on MCA portal (within 15 days of SRN generation)
- Pay Fees within 7 days of successful PDF upload, or due date + 2 days, whichever is earlier
- Receive acknowledgement
Option 2: Via MCA Search Bar
Search for “CHG-9” on the MCA homepage and proceed from Step 3 above.
Resubmission Process
Option 1 — Via Dashboard:
- Login → Application History
- Select CHG-9 with status ‘Resubmission Required’
- Fill, submit, affix DSC, and upload within 15 days of BO marking resubmission
Option 2 — Via Notification Email:
- Click the link in the resubmission email
- Login, fill, submit, affix DSC, and upload
Daily SMS and email reminders are sent if DSC-affixed PDF is not uploaded within 24 hours of SRN update, for up to 15 days.
Field-Level Instructions
Field 1: CIN / FCRN
- Company users: auto-populated
- Professional users: searchable by company name
- Other business users: dropdown of associated CINs
- Must be valid
Field 3(a): Purpose of the Form
- Creation of charge / Modification of charge / Rectification of charge
Field 3(b): Rectification Details
- Displayed and mandatory only if ‘Rectification’ is selected in Field 3(a)
- At least one option must be selected
Field 3(c): Type of Debentures
- Mandatory for creation, modification, or rectification of ‘Type of debenture’
Field 3(d): SRN of Form for Rectification
- Mandatory for rectification
- Must be a valid, approved SRN associated with the company’s CIN/FCRN
Field 3(e): Charge ID for Modification or Rectification
- Mandatory for modification or rectification
- Pre-filled from SRN if provided in Field 3(d); non-editable if pre-filled
- Must be a valid Charge ID associated with the company’s CIN
Field 3(f): SRN of CHG-8
- Mandatory for rectification
- Must be a valid, approved CHG-8 SRN associated with the company’s CIN/FCRN
Field 5(a): Date of Instrument Creating or Modifying the Charge
- Mandatory for creation or modification
- Charge holder/trustee cannot file before 30 days from this date
- Filing not permitted beyond 120 days from this date
- Must be ≥ date of charge creation or last modification for the Charge ID
- Must be ≤ current date
Field 7(a): Description of Property Charged
- At least one option must be selected from the checkboxes
Field 8: Number of Trustees of Debenture Holders / Charge Holders
- Displayed for rectification when ‘Number of trustees or debenture holders’ is selected in Field 3(b)
- Must be ≥ 1
Field 9: Charge Holder / Trustee Details
- CIN (if applicable): Must be valid and different from Field 1 CIN
- Name: Pre-filled from company master based on CIN
- PAN: Mandatory if charge holder/trustee is an Indian entity (‘Yes’ auto-selected for India)
- Must be a valid income tax PAN
Field 10(c)(i): Total Amount Secured by Whole Series
- Mandatory if debenture series is registered with RoC
- Must be > 0
Field 10(c)(ii): Date of Registration of Series
- Mandatory if series is registered with RoC
- Must be ≤ current date
Field 10(d): Date of Present Issue of Series
- Mandatory for creation or rectification of ‘particulars related to present issue of series’
- Must be ≤ current date
Field 10(e): Maximum Amount of Present Issue (Amount Secured)
- Mandatory for creation/modification or rectification of present issue particulars
- Must be a positive integer ≤ total amount secured by the whole series (Field 10(c)(i))
- For modification: enter the amount after modification
Field 11(a): SRN of MGT-14
- Mandatory if ‘Yes’ is selected in Field 11 (resolution for debenture issue filed in MGT-14)
- Must be a valid MGT-14 SRN associated with the company’s CIN
Field 11(b): Date of Resolution Authorising Issue of Series
- Pre-filled from MGT-14 if SRN is provided; non-editable if pre-filled
- Must not exceed the date of registration of series
- Must be < current date
Field 12(a): Date of Security Interest by Deposit of Title Deeds
- Must be ≤ current date
Field 14: Number of Title Documents Deposited
- Only positive integers up to 10 are allowed
- Fields ‘Document Type’ to ‘State/UT’ regenerate based on the number entered
Mandatory Attachments
| Attachment | Mandatory? |
|---|---|
| Instrument(s) of creation or modification of charge | Mandatory |
| Copy of resolution authorising issue of debenture series | Mandatory if ‘Creation’ is selected AND resolution not filed in MGT-14 (‘No’ in Field 11) |
| Optional attachments (up to 5) | Optional |
- Format: PDF or JPG; max 2 MB per file; total up to 10 MB
Signing Requirements
Company Declaration
- Mandatory if applicant is the company
- Board resolution number and date; date must be ≥ incorporation/establishment date and ≤ system date
- Additional checkbox declaration required if: (a) filing is delayed beyond 30 days and filed by the company, or (b) Trustee is the applicant and the checkbox is selected
- Signed by: Director / Manager / CS / CEO / CFO / IRP/RP/Liquidator (Indian company) or Authorised Representative (foreign company)
- IRP/RP/Liquidator: available only for Rectification or Modification; company must be ‘Under CIRP’ or ‘Under Liquidation’
Charge Holder or Trustee of Debenture Holders
- PAN mandatory (unless exempt as multilateral/international financial institution)
- Form must be signed by charge holder or trustee if applicant is charge holder or trustee
ARC or Assignee
- Mandatory if charge is modified in favour of ARC or assignee
- Valid PAN required
Any Other Person (for Rectification)
- For rectification filings, any person may digitally sign the form
- Designation and valid PAN are mandatory
Professional Certification
- Mandatory for all companies except OPC and Small Companies (optional for them)
- Certified by: CA (WTP) / CMA (WTP) / CS (WTP)
- CA/CMA: membership number; CS: Certificate of Practice number
Fee Structure
Normal Fee — Companies with Share Capital
| Nominal Share Capital (INR) | Fee (INR) |
|---|---|
| Less than 1,00,000 | 200 |
| 1,00,000 to 4,99,999 | 300 |
| 5,00,000 to 24,99,999 | 400 |
| 25,00,000 to 99,99,999 | 500 |
| 1,00,00,000 or more | 600 |
Companies without Share Capital: ₹200
Foreign Companies: ₹6,000
Note: No additional or delay fee applies to rectification filings.
Additional (Delay) Fee — Creation or Modification Only
Filing must be within 30 days from the date of creation/modification.
| Period of Delay | Small Companies & OPC | Other Companies |
|---|---|---|
| Up to 30 days | 3× normal fee | 6× normal fee |
| More than 30 days up to 90 days | 3× normal fee + ad valorem @ 0.025% of amount secured (max ₹1 lakh) | 6× normal fee + ad valorem @ 0.05% of amount secured (max ₹5 lakhs) |
Maximum filing window: 120 days from the date of creation/modification. Beyond that, CHG-8 must be filed first.
Processing Mode
CHG-9 is processed in Non-STP mode — involving manual review by the Registrar of Companies.
CHG-9 vs CHG-1: Key Differences
| Parameter | CHG-9 | CHG-1 |
|---|---|---|
| Applicable to | Charges for debentures only | All other charges (non-debenture) |
| Governing sections | 71(3), 77, 78, 79 | 77, 78, 79 |
| Rectification option | Yes (within same form) | No separate rectification option |
| Debenture series details | Required | Not applicable |
| MGT-14 SRN linkage | Required (if resolution filed) | Not required |
Useful Links
Frequently Asked Questions (FAQs)
Q1. What is the difference between CHG-9 and CHG-1? CHG-9 is specifically for charges created in connection with debentures, while CHG-1 covers all other types of charges (loans, mortgages, etc. not involving debentures).
Q2. Can rectification be done directly in CHG-9? Yes. Unlike CHG-1 (where errors require a separate CHG-8 application), CHG-9 has a built-in rectification option. However, an approved CHG-8 SRN is still required as a prerequisite for rectification filing in CHG-9.
Q3. What is the role of the debenture trustee in CHG-9? A debenture trustee acts as the charge holder on behalf of the debenture holders. They can file CHG-9 and must sign the form using their PAN-linked DSC. Filing by the trustee is not permitted before 30 days from the date of creation/modification.
Q4. Does CHG-9 need to be linked to a board resolution? If the resolution authorising the issue of the debenture series has been filed in MGT-14, the MGT-14 SRN must be linked in Field 11(a). If no MGT-14 has been filed, a copy of the resolution must be attached as a mandatory attachment.
Q5. What is the maximum time allowed for filing CHG-9 for creation/modification? 120 days from the date of creation/modification. After that, an application for condonation must be made to the Regional Director via CHG-8 before CHG-9 can be processed.
Q6. Is there a fee for rectification filings in CHG-9? Yes, the normal filing fee applies to rectification. However, no additional delay fee is charged for rectification.
Disclaimer
This article is based on the official Instruction Kit published by the Ministry of Corporate Affairs (MCA), Government of India. While every effort has been made to ensure accuracy, the content is intended for general guidance purposes only. MCA forms, rules, and fee structures are subject to change through amendments to the Companies Act, 2013 or notifications issued thereunder.
In case of any inconsistency or doubt, readers are advised to refer to the official MCA helpkit and resources available on MCA website.