Form PAS-6 MCA: Complete Guide to Reconciliation of Share Capital Audit Report

Introduction link

Form PAS-6 is a critical compliance requirement under Companies Act, 2013. It is a half-yearly return used for the reconciliation of share capital audit — specifically detailing shares held in dematerialized (Demat) form.

Originally applicable only to unlisted public companies, the scope of PAS-6 has been significantly expanded. Effective October 1, 2024, the requirement now also covers non-small private companies, making this one of the most impactful recent changes in routine corporate compliance.

This guide walks you through everything you need to know: the legal background, who must file (and from when), how to file step-by-step, and how to make payment — both online and offline.

What is Form PAS-6? link

Form PAS-6, officially titled the “Reconciliation of Share Capital Audit Report (Half-yearly)”, is an electronic filing form on the Ministry of Corporate Affairs (MCA) portal. Its primary purpose is to streamline the process by which companies report the status of their shares — specifically, how many shares are held in Demat form versus physical form.

Key Purpose link

To simplify the half-yearly return process for reporting of shares held in Demat form.

Legal Basis link

Form PAS-6 is governed by:

• The Companies Act, 2013
• Sub-Rule 8 of Rule 9A of The Companies (Prospectus and Allotment of Securities) Rules, 2014
• MCA Notification / Amendment Rules extending applicability to private companies, effective October 1, 2024

What the Law Requires link

Every company to which these rules apply must:

1. Submit Form PAS-6 to the Registrar of Companies (RoC)
2. File within 60 days from the conclusion of each half year
3. Have the form duly certified by either:
   • A Company Secretary in practice, or
   • A Chartered Accountant in practice

Important: The additional (delay) fee, as applicable, will be levied until the date payment is confirmed and acknowledgment is generated.

Who Needs to File PAS-6? link

The applicability of Form PAS-6 has been expanded in two phases:

Phase 1 — Original Applicability link

All unlisted public companies were required to file from the time Rule 9A came into force.

Phase 2 — Extended to Private Companies (w.e.f. October 1, 2024) link

Non-small private companies are now also required to file Form PAS-6, effective for the half year beginning October 1, 2024.

What is a “Small Company”? link

A private company qualifies as a small company under Section 2(85) of the Companies Act, 2013 if it meets both of the following thresholds (as amended):

• Paid-up share capital does not exceed ₹ 10 crore, AND
• Turnover does not exceed ₹ 100 crore (as per the last profit and loss account)

⚠️ Important for Private Companies: If your private company exceeds either of these thresholds, it is classified as a non-small private company and is mandatorily required to file PAS-6 from October 1, 2024 onwards.

First Filing Deadline for Private Companies link

The first half year for which private companies must file is October 1, 2024 – March 31, 2025, with a filing deadline of May 29, 2025 (60 days from March 31, 2025).

Filing Deadlines link

📌 Note for Private Companies: The obligation to file begins from the half year October 1, 2024 – March 31, 2025. Private companies are not required to file retrospectively for periods before October 1, 2024.

Step-by-Step Guide to Filing PAS-6 link

Step 1: Access the MCA Portal link

To navigate to the PAS-6 form on the MCA website:

1. Go to MCA Services in the top navigation menu
2. Click on Company e-Filing
3. Select Compliance Services
4. Click on PAS-6 – Reconciliation of Share Capital Audit Report

Direct URL path:

MCA Portal → MCA Services → Company e-Filing → Compliance Services → PAS-6

Step 2: Login to MCA link

Before filing, you must be logged in to the MCA portal.

• Click the Sign In / Sign Up tab in the top navigation bar
• Enter your User ID:
  • CIN/FCRN/LLPIN for company/LLP users
  • Email ID for other users
• Enter your Password and click Login

Once logged in, you can access all MCA services including e-Form uploads, payments, and annual e-Filings from My Workspace.

Step 3: Fill in Company Details (Page 1 of the Form) link

On the e-Filing Form PAS-6, enter the following details:

Company Identification link

• CIN (Corporate Identity Number) — OR — Search by Company Name to auto-fetch the CIN
• The following fields auto-populate once CIN is entered:
  • Name of the Company
  • Address of Registered Office
  • Email ID of the Company

Filing Details link

• Period of Filing: Enter the From and To dates for the half year

Share Capital Details link

• Number of classes of shares / securities (e.g., 1 for equity only)
• Details of shares per class:
  • Type of Security (Equity / Preference)
  • Class of Shares
  • ISIN number

Share Holdings Breakdown (as per the table) link

• Reasons for shares held in physical form (if applicable)

Click Next to proceed.

Step 4: Fill in Share Capital Changes & Promoter Holdings (Page 2) link

Changes in Share Capital During the Half Year link

Fill in the table for each type of capital change, including whether it was intimated to NSDL and CDSL:

Details of Shares Held By: link

Additional Fields link

• Whether the Register of Members is updated: Yes / No
• Details of Demat requests:
  • Confirmed after 21 days
  • Pending for more than 21 days (with reasons for delay)
• Whether there is appointment of common agency for share registry work: Yes / No
  • If Yes, provide the name of the R&T (Registrar and Transfer) agency
• Any other details the professional may want to provide

Click Next to proceed.

Step 5: Attachments & Declarations (Page 3) link

Attachments link

• Upload any optional attachments (if applicable)
• Maximum file size: 2 MB

Verification Section link

Fill in:

• Board resolution number and date authorizing the signatory
• Designation of the signatory
• DIN (Director Identification Number) of the Director or Managing Director — OR —
• DIN/PAN of the Manager / CEO / CFO
• Membership number of the Company Secretary

Certificate by Practicing Professional link

The practicing professional must certify:

“I hereby certify 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 attachments) from the original records maintained by the Company, which is subject matter of this form and found them to be true, correct and complete…”

The professional must also certify:

• (a) Records have been properly prepared, signed, and maintained per the Companies Act, 2013
• (b) All required attachments are completely and legally attached
• (c) They understand liability under Section 448 of the Companies Act, 2013 for wrong certification

Who can digitally sign as the practicing professional?

• Chartered Accountant (in wholetime practice)
• Company Secretary (in wholetime practice)

Additional fields:

• Whether Associate or Fellow
• Membership number
• Certificate of Practice (CP) number

⚠️ Note: Attention is drawn to Sections 448 and 449 which provide for punishment for false statements and certification.

Click Next to proceed to the Review page.

Step 6: Review and Submit link

• Carefully review the complete form before submitting
• Once satisfied, click the Submit button

Upon successful submission:

• A Service Request Number (SRN) is generated (e.g., AA0012652)
• A confirmation message appears: “The request for Form PAS-6 has been submitted against SRN XXXXXXXX”
• Click OK to proceed

Note: The filing status will be confirmed only after successful DSC (Digital Signature Certificate) verification and payment confirmation.

Step 7: Download PDF and Affix DSC link

After submission:

1. Navigate to My Application in the top menu bar
2. Locate your PAS-6 filing (Status: Pending for DSC Upload and Payment)
3. Click Download PDF to download the generated form
4. Affix the DSC (Digital Signature Certificate) of the authorised company representative on the PDF
5. Upload the DSC-affixed PDF document (Maximum size: 10 MB)
6. Once uploaded successfully, click Proceed to Payment

Step 8: Payment link

The filing fee for PAS-6 is specified under The Companies (Registration of Offices and Fees) Rules, 2014:

The additional fee applies if filing is done after the 60-day deadline from the close of the half year.

You can pay either Online or Offline.

Online Payment Mode link

1. Select Online as the payment mode and click Submit
2. Verify your Depositor’s Details (name, address, email, TAN, TIN)
3. Verify the Purpose Details:
   • Ministry: Corporate Affairs
   • PAO: PAO Corporate Affairs, New Delhi [086000]
   • DDO: DDO[286001]
   • Payment Type: All Forms, One Time
4. Click Confirm
5. Select a Payment Gateway (Axis Bank, Union Bank, Bank of Baroda, HDFC Bank, Indian Bank, ICICI Bank, SBI ePay, Kotak, etc.)
6. Select a Payment Mode: Net Banking, Debit Card, Credit Card, or UPI
7. Enter the CAPTCHA text
8. Check the acknowledgement box: “I acknowledge and confirm that I have read and agree to the Terms And Conditions”
9. Click Pay
10. Complete the bank’s authentication (e.g., enter OTP from your bank)
11. Wait for payment processing — do not press Back or Refresh
12. On successful payment, a Transaction Successful confirmation is shown
13. A payment receipt (G.A.R. 7) is automatically generated by MCA

💡 Tip: Use the ‘Track Payment Status’ functionality under MCA Services → Fee & Payment Services to check transaction status if you don’t receive confirmation within 30 minutes.

Offline Payment Mode (NEFT/RTGS) link

For companies that prefer offline payment:

1. Select Offline as the payment mode and click Submit
2. Click Proceed on the NEFT information page
3. An E-Challan is generated (for offline payment — not for use at bank counter)
4. Enter your Bank Account details on the NTRP Portal:
   • Bank Account Number
   • Bank Name
   • IFSC Code
5. Click Submit to Validate Account
6. After validation, confirm the payment details and click Confirm
7. Download the Depositor Slip PDF
8. Take the printout to your bank to process the NEFT/RTGS transaction
9. The bank will provide a UTR (Unique Transaction Reference) number upon successful transfer
10. Link the UTR number to the UTR number on the NTRP portal within 7 days of NEFT challan generation (or two days after due date, whichever is earlier)

⚠️ Important: If linking is not completed within 7 days (or two days after due date, whichever is earlier), the transaction will be cancelled. The deposit slip is valid for 15 days from creation.

After Successful Payment link

Once payment is confirmed:

• A G.A.R. 7 Receipt is generated by MCA
• The receipt contains:
  • SRN number
  • Receipt date
  • Depositor’s details
  • Entity details (CIN, company name, address)
  • Fee breakdown (Normal + Additional fees)
  • Mode of Payment
• You can download this receipt from My Application → Application History

Common Mistakes to Avoid link

1. Missing the 60-day deadline — This triggers a heavy additional fee of ₹7,200
2. Incorrect ISIN — Verify the ISIN for each class of share before filing
3. Not updating physical share reasons — If shares remain in physical form, reasons must be provided
4. Forgetting to affix DSC — The form is not considered filed until DSC is uploaded
5. Not tracking payment via UTR — For offline payments, failure to link UTR within 7 days cancels the transaction
6. Mismatch in share capital numbers — Ensure the total tally matches across all categories
7. Private companies assuming exemption — Non-small private companies must file from October 1, 2024; assuming you are a “small company” without verifying the current thresholds (₹4 crore paid-up capital AND ₹40 crore turnover) is a common and costly error
8. Ignoring threshold changes — Small company thresholds are periodically revised by the MCA; always verify the current limits before concluding you are exempt

Quick Reference Checklist link

Use this checklist before and during filing:

• Confirm applicability — Unlisted public company, OR private company with paid-up capital > ₹4 crore OR turnover > ₹40 crore
• Private companies: Confirm obligation starts from the Oct 1, 2024 – Mar 31, 2025 half year
• Identify the half-year period (Apr–Sep or Oct–Mar)
• Calculate the filing deadline (60 days from period end)
• Gather CIN, ISIN, and share capital data
• Prepare share-wise breakdown (CDSL, NSDL, Physical)
• List all capital changes during the half year
• Prepare promoter/director/KMP shareholding details
• Engage a practicing CA or CS for certification
• Obtain Board resolution authorizing signatory
• Log in to MCA portal and fill the form
• Review and submit the form
• Download PDF and affix DSC
• Upload DSC-affixed PDF
• Complete payment (online or offline)
• Download and save the payment receipt (G.A.R. 7)

Key Contacts and Resources link

Summary link

Form PAS-6 is a critical compliance requirement whose applicability has been significantly expanded in recent years. The key points to remember:

• Who: Every unlisted public company and every non-small private company (w.e.f. October 1, 2024)
• What: Reconciliation of Share Capital Audit Report
• When: Within 60 days of each half year end
• First deadline for private companies: May 29, 2025 (for the Oct 1, 2024 – Mar 31, 2025 half year)
• Certified by: Practicing CA or CS
• Filed with: Registrar of Companies via MCA portal
• Fee: ₹600 (normal) + ₹7,200 (if delayed) = ₹7,800 total if late
• Legal basis: Sub-Rule 8 of Rule 9A of Companies (Prospectus and Allotment of Securities) Rules, 2014

For private companies that previously had no PAS-6 obligation, this expansion is a significant new compliance burden. Timely filing not only ensures legal compliance but also avoids the substantial additional fees that accrue for late submissions.

This article is based on the MCA Form PAS-6 Guide by MCA. Always verify with the latest MCA guidelines and instructions before filing.