Form GNL-4 is the web form used to file an addendum for rectification of defects or incompleteness in a webform already submitted to the MCA. It is governed by Rule 10 of the Companies (Registration Offices and Fees) Rules, 2014.

In certain cases, the back-office examiner at MCA may require the applicant to furnish clarifications or additional documents in support of a form already filed. Such clarifications or documents are submitted through GNL-4 as an addendum to the original (parent) webform.

Note: GNL-4 cannot be used in respect of any webform filed under Straight Through Process (STP) mode. It is available only where the SRN status of the relevant company or foreign company webform is ‘Pending user clarification (PUCL)’.

Who Should File GNL-4 / When is it Filed

  • Any applicant whose previously filed webform has been marked ‘Pending user clarification (PUCL)’ by the MCA back-office user, and who needs to submit the clarification or additional document sought
  • Applicable to companies, foreign companies, and even a company yet to be incorporated (e.g., where the PUCL relates to an incorporation-stage webform such as INC-1, DIR-12, INC-22, URC-1, INC-12, or RD-1)
  • Used to provide an additional (differential) stamp duty payment SRN where required by the examiner
  • Not usable for any webform that was originally processed in STP mode, since STP forms are taken on record without manual scrutiny and therefore cannot generate a PUCL query

Important Checkpoints Before Filing

  • Applicant must be registered on the MCA portal before filing
  • The company or foreign company for which GNL-4 is being filed must be registered with MCA and hold a valid, approved CIN/FCRN (not applicable where the parent webform relates to a company yet to be incorporated)
  • The DSC attached must be registered on the MCA portal against the DIN/DPIN/PAN/Membership number entered in the form
  • The signing authority must hold a valid, non-expired, non-revoked DSC and an approved DIN/DPIN, or a valid PAN/membership number, as applicable
  • GNL-4 cannot be filed against any webform filed under STP mode
  • GNL-4 can only be filed where the SRN status of the relevant webform is ‘Pending user clarification (PUCL)’
  • The relevant SRN marked PUCL must be available with the user at the time of filing
  • GNL-4 must be filed within fifteen days from the date the parent SRN was marked PUCL
  • Additional details that do not fit within a field may be provided as an optional attachment
  • Check the “Notifications and alerts” section under ‘My Workspace’ on the MCA FO user dashboard for any relevant alerts

Step-by-Step Filing Process

Option 1: Via MCA Services Menu

  1. Access the MCA homepage and log in with valid credentials
  2. Go to MCA Services → E-Filing → Company Forms Download
  3. Navigate to the header “Filing of application/documents with RoC”
  4. Access “Form for filing Addendum for rectification of defects or incompleteness (GNL-4)”
  5. Enter the CIN/FCRN (searchable for professional users; dropdown for other business users)
  6. Fill up the application
  7. Optionally save the webform as a draft (enabled once CIN/FCRN is entered)
  8. Submit the webform
  9. Note the SRN generated — usable for all future correspondence with MCA
  10. Affix the DSC
  11. Upload the DSC-affixed PDF on the MCA portal — must be completed within 15 days of SRN generation, or the SRN will be cancelled
  12. Receive the acknowledgement

Search “GNL-4” on the MCA homepage and proceed through login, CIN/FCRN entry, fill-up, submission, DSC affixation, and upload as in Option 1.

SRN Cancellation: If the DSC-affixed PDF is not successfully uploaded within 15 days of SRN generation, the SRN stands cancelled.

Field-Level Instructions

Field 1: SRN of Relevant Form(s)

Enter a valid SRN having status ‘Pending user clarification (PUCL)’ for which the addendum is being filed. This is the anchor field that drives most of the prefill logic in the rest of the form.

Field 3/4(a): CIN/FCRN and Company Details

  • CIN/FCRN in Field 3 is prefilled and mandatory only where the SRN entered in Field 1 relates to an existing company or foreign company
  • Name of company (4(a)), registered office address (4(b)), and email ID (4(d)) are all prefilled and non-editable based on the CIN/FCRN
  • For incorporation webforms (INC-1, DIR-12, INC-22, URC-1, INC-12, RD-1), the name of the proposed company is displayed instead
  • Field 4(c) — name of the person filing the form — is mandatory only where the SRN does not relate to an existing company or a company yet to be incorporated

Field 6(a): SRN of Additional (Differential) Stamp Duty Payment

Enter a valid SRN of additional stamp duty payment. This SRN must correspond to the SRN of the relevant webform entered in Field 1.

Signing Designation Logic

GNL-4 supports signing by a wide variety of persons depending on the nature of the parent webform:

  • Company/LLP representatives: Managing Director / Director / Manager / Company Secretary / CEO / CFO / Authorised representative / Authorised person / Designated partner — requiring DIN, PAN, or membership number as applicable to the role selected
  • Director or Member — DIN for director; DIN or PAN for member
  • Charge holder / Applicant / Promoter / Liquidator / Individual / Partner / Auditor / Partner of auditor’s firm — PAN or membership number depending on role (optional for Liquidator)
  • ARC or Assignee / Chairman / Person charged / Others — DIN, PAN, or membership number as applicable

Certificate by Practicing Professional

Applicable only where professional certification was applicable in the underlying webform for which GNL-4 is filed. The webform must then be certified by a CA (whole-time practice), CMA (whole-time practice), or CS (whole-time practice), entering their membership number or Certificate of Practice number as applicable.

Mandatory Attachments

AttachmentMandatory?
Documents/clarifications sought against the PUCL queryAs per requirement (selected under “Type of document” dropdown)
Optional attachment(s), up to fiveOptional
  • All attachments must be in PDF or .jpg format; each individual attachment can be up to 2 MB
  • Total size of all documents submitted can be up to 10 MB
  • Up to five attachments may be uploaded

Signing Requirements

GNL-4 is signed by the same category of person who would ordinarily be authorised to sign the parent webform — Director, Managing Director, Manager, CEO, CFO, Company Secretary, Authorised Representative/Person, Designated Partner (LLP), Charge holder, Promoter, Liquidator, Auditor, ARC/Assignee, Chairman, or Person Charged, depending on the nature of the underlying filing. Where the parent webform required professional certification, the same category of professional (CA/CMA/CS in whole-time practice) must digitally certify GNL-4 as well.

Fee Structure

This section is not applicable. GNL-4 does not attract any filing fee.

Processing Mode

GNL-4 is always processed in Non-STP mode and is linked to the main (parent) form — whose SRN is provided in the webform — which itself must also be a non-STP form.

Frequently Asked Questions (FAQs)

Q1. What does ‘Pending user clarification (PUCL)’ mean? PUCL is an SRN status assigned by the MCA back-office user when the department requires additional clarification or documents before it can process a filed webform. GNL-4 is the mechanism to respond to such a query.

Q2. Can GNL-4 be filed against a form that was processed in STP mode? No. GNL-4 is expressly not available for webforms filed under Straight Through Process (STP) mode, since such forms are taken on record electronically without manual scrutiny and therefore cannot be marked PUCL.

Q3. What is the time limit for filing GNL-4? GNL-4 must be filed within fifteen days from the date the parent SRN was marked ‘Pending user clarification (PUCL)’.

Q4. Is there any fee for filing GNL-4? No. The fee rules section for GNL-4 is not applicable — there is no filing fee.

Q5. Can GNL-4 be filed for a company that is yet to be incorporated? Yes. Where the PUCL relates to an incorporation-stage webform, GNL-4 can be filed even though the company does not yet have a CIN.

Q6. What happens if I miss the 15-day window to upload the DSC-affixed PDF? The SRN generated for GNL-4 will be cancelled if the DSC-affixed PDF is not successfully uploaded within 15 days of SRN generation.

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.