Form PAS-6: Complete Guide to Half-Yearly Return for Reporting of Shares Held in Demat Form
Form PAS-6 is the half-yearly web form through which an unlisted public company files its Reconciliation of Share Capital Audit Report with the Registrar of Companies (RoC). It is governed by Sub-rule 8 of Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014.
Every unlisted public company covered by Rule 9A must submit this form within sixty days from the conclusion of each half year, duly certified by a company secretary in practice or a chartered accountant in practice.
Note: Nidhi Companies, Government Companies, and Listed Companies are not required to file PAS-6.
Who Should File PAS-6 / When is it Filed
- Every unlisted public company governed by Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014
- Filed half-yearly, for the periods 1 April to 30 September and 1 October to 31 March, within 60 days from the conclusion of each half year
- Not applicable to Nidhi Companies, Government Companies, or Listed Companies
Important Checkpoints Before Filing
- Applicant must be registered as a Business User on the MCA portal before filing
- The company must be registered with MCA and hold a valid CIN
- DSC attached must be registered on the MCA portal against the DIN/PAN/Membership Number provided
- Authorised signatories must have an approved DIN, valid PAN, or valid Membership Number, as applicable, and a valid, non-expired, non-revoked DSC
- DIN entered in the verification section must not be flagged for disqualification
- PAS-6 must not already have been filed for the same reporting period
- The membership/certificate of practice number of the certifying professional must be valid and the professional must not be debarred
- Additional details that don’t fit within a field can be provided as an optional attachment
Step-by-Step Filing Process
Option 1: Via MCA Services Menu
- Login to the MCA portal
- Go to MCA Services → E-Filing → Company Forms Download
- Navigate to the header “Intimation regarding allotment of securities”
- Access “Half yearly return for reporting of shares held in Demat form (PAS-6)”
- Enter Company Information (CIN auto-populated for company users; searchable for professionals; dropdown for other business users)
- Fill up the application
- Optionally save as draft (enabled once CIN is entered)
- Submit the webform
- Note the SRN generated
- Affix DSC on the generated PDF
- Upload DSC-affixed PDF on MCA portal
- Pay Fees — within 15 days of SRN generation for upload and within 7 days of successful upload for payment, or due date of filing + 2 days, whichever is earlier. Failing this, the SRN is cancelled
- Receive acknowledgement
Option 2: Via MCA Search Bar
Search “PAS-6” on the MCA homepage and proceed from Step 3 above (login, then same steps).
There is no provision for resubmission for this webform — it is processed entirely in STP mode.
Field-Level Instructions
Field 3: Period of Filing (From / To)
- The ‘From’ date cannot exceed T-1 day, where T is the last day of the last concluded semiannual period, and cannot itself be 30 September or 31 March
- Semiannual periods run 1 April–30 September and 1 October–31 March
- If ‘From’ falls between 1 April and 29 September, ‘To’ auto-fills as 30 September of the same year; if ‘From’ falls between 1 October and 30 March, ‘To’ auto-fills as 31 March
Field 5(c): ISIN
- Prefilled from the share capital master where available; must be entered manually otherwise
- Must be a valid 12-digit alphanumeric ISIN registered in India
- If edited, the ISIN is updated against that class of share in the share capital master
Field 5(d): Number of Shares Held in Dematerialized Form (CDSL/NSDL)
- Cannot be left blank (zero is allowed), and negative/decimal values are not permitted
- The sum of CDSL + NSDL demat holdings cannot exceed the ‘Total no. of issued shares’ for that class
- If a previous PAS-6 was filed for an earlier period, these values are prefilled from that filing but remain editable
Field 5(g): Demat/Physical Holdings — Promoters, Directors, KMP
- Values cannot exceed the total dematerialized shares for the class (per Field 5(d)), and the combined total for Promoters + Directors + KMP cannot exceed that figure
- Negative values are not permitted; zero is allowed
Mandatory Attachments
| Attachment | Mandatory? |
|---|---|
| Optional attachment(s) (up to 5) | Optional |
- Format: PDF or JPG; up to 2 MB per individual attachment
- There is no separately mandatory attachment beyond the data fields — reconciliation figures are entered directly in the form
Signing Requirements
- Signed by: Director / Manager / CEO / CFO / Company Secretary
- The signatory’s DSC must be registered with MCA before signing
- Director: enter approved DIN. Manager/CEO/CFO: enter approved DIN or valid income-tax PAN. Company Secretary: enter valid membership number
- Certification by a Chartered Accountant (whole-time practice) or Company Secretary (whole-time practice) is required — the certifying category is prefilled from the dropdown selected under verification, with the professional’s Associate/Fellow status and membership/Certificate of Practice number to be entered
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 |
Additional (Delay) Fee
Event date: conclusion of each half year (31 March / 30 September). Filing window: 60 days.
| Period of Delay | Additional Fee |
|---|---|
| Up to 30 days | 2× normal fee |
| More than 30 days and up to 60 days | 4× normal fee |
| More than 60 days and up to 90 days | 6× normal fee |
| More than 90 days and up to 180 days | 10× normal fee |
| More than 180 days | 12× normal fee |
Processing Mode
Form PAS-6 is processed in STP mode and taken on record through electronic mode without any further processing. Ensure all particulars are correct — there is no provision for resubmission of this webform.
Useful Links
Frequently Asked Questions (FAQs)
Q1. Which companies are exempt from filing PAS-6? Nidhi Companies, Government Companies, and Listed Companies are not required to file PAS-6 — it applies specifically to unlisted public companies.
Q2. What is the filing deadline for PAS-6? Within 60 days from the conclusion of each half year (i.e., by 29/30 May for the April–September half and by 29/30 November for the October–March half).
Q3. Who can certify PAS-6? A company secretary in practice or a chartered accountant in practice, both in whole-time practice.
Q4. Can PAS-6 be filed twice for the same reporting period? No — the system checks and blocks a second filing for a period that has already been reported.
Q5. What validation applies to the number of dematerialized shares reported? The combined CDSL + NSDL demat holdings for a class of shares cannot exceed the total issued shares for that class, and negative or decimal values are not accepted.
Q6. Is there a resubmission option if PAS-6 is filed with errors? No. PAS-6 is processed in STP mode with no resubmission facility, so all reconciliation figures must be verified before submission.
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.