Form PAS-7: Complete Guide to Filing Details of Pending Share Warrants
Form PAS-7 is the web form filed with the Registrar of Companies to report pending share warrants — those issued by a public company before the commencement of the Companies Act, 2013, and not yet converted into shares. It is governed by the notification dated 27 October 2023 issued under Section 114 of the Companies Act, 1956, read with Rule 9 of the Companies (Prospectus and Allotment of Securities) Rules, 2014.
Time limit: Filing must be completed within three months of the commencement of the Companies (Prospectus and Allotment of Securities) Second Amendment Rules, 2023.
Who Should File PAS-7 / When is it Filed
Every public company that issued share warrants prior to the commencement of the Companies Act, 2013, and which have not since been converted into shares, must inform the Registrar of the details of such pending share warrants in Form PAS-7.
Important Checkpoints Before Filing
- Applicant must be registered on the MCA portal, and the company must have a valid, approved CIN
- DSC must be registered on the MCA portal against the DIN/PAN/Membership number provided
- Signatory’s DIN must not be flagged for disqualification
- The form must not be signed by a Director/Manager/Company Secretary/CEO/CFO in respect of whom a pending DIR-12/Form 32 (for cessation) is awaiting payment or approval
- Only up to 10 approvals sought from the Central Government can be filed in a single e-form
Step-by-Step Filing Process
- Login to MCA portal → MCA Services → Company e-Filing → Compliance Services
- Access “PAS-7 (Filing in respect of Details of pending share warrants)”
- Enter/search/select CIN
- Fill up the application
- Optionally save as draft
- Submit the webform and note the SRN
- Affix DSC
- Upload the DSC-affixed PDF on MCA portal
- Pay Fees (within the standard upload/payment windows)
- Receive acknowledgement
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
Applicable after expiry of 3 months from the date of publication of the notification in the Official Gazette.
| Period of Delay | Additional Fee |
|---|---|
| Up to 30 days | 2× normal fee |
| More than 30 up to 60 days | 4× normal fee |
| More than 60 up to 90 days | 6× normal fee |
| More than 90 up to 180 days | 10× normal fee |
| More than 180 days | 12× normal fee |
Processing Mode
Form PAS-7 is processed in STP mode — taken on record electronically without further processing. There is no provision for resubmission.
Useful Links
Frequently Asked Questions (FAQs)
Q1. What are “share warrants” in this context? Instruments issued by a public company before the Companies Act, 2013, entitling the bearer to shares, which have not yet been converted into actual shares.
Q2. How many pending share warrant approvals can be filed in one PAS-7? Up to 10 Central Government approvals per e-form.
Q3. What was the original filing deadline? Within 3 months of the commencement of the Companies (Prospectus and Allotment of Securities) Second Amendment Rules, 2023.
Q4. Is PAS-7 processed automatically? Yes, it is processed in STP mode with no resubmission facility.
Q5. What happens if PAS-7 is filed after the deadline? Additional fee applies on a sliding scale from 2 times up to 12 times the normal fee, computed from the expiry of the 3-month window.
Disclaimer
This article is based on the official Instruction Kit for Form PAS-7 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 access page for PAS-7 and resources available on the MCA website.