Form INC-20: Complete Guide to Revocation/Surrender of License Granted Under Section 8
Form INC-20 is the web form filed with the Registrar of Companies to register the revocation or surrender of a license granted to a company under Section 8 of the Companies Act, 2013. It is governed by Sections 4, 5 and 8 of the Companies Act, 2013 read with Rules 22 and 23 of the Companies (Incorporation) Rules, 2014.
A license granted to a Section 8 company can be revoked either by the Central Government or, on the company’s own request (suo motu), by applying to the Regional Director (RD) via Form INC-18. Once the Central Government or RD orders the revocation, the order must be registered with the RoC through INC-20 — after which a fresh Certificate of Incorporation (COI) is issued and the company converts from a Section 8 company into any other kind of company, along with the associated change of name.
Who Should File INC-20 / When is it Filed
Any company registered under Section 8 whose license has been ordered revoked by the Central Government, or which has itself applied for and been granted surrender of its license by the Regional Director, must file INC-20 to register that order with the RoC.
Important Checkpoints Before Filing
- Applicant must be registered on the MCA portal before filing the webform
- The company must be registered with MCA as a Section 8 company and hold a valid, approved CIN
- In case of resubmission, the application must be available in the user’s application history, and T+15 days (T being the date marked ‘Resubmission Required’) must not have elapsed
- DSC affixed to the webform, eMOA, and eAOA must be registered on the MCA portal against the DIN/PAN/Membership number provided
- The applicant filing the webform must be registered at the MCA portal
- The signing authority must hold a valid, non-expired, non-revoked DSC
Step-by-Step Filing Process
- Login to MCA portal → MCA Services → E-Filing → Company Forms Download
- Access “Form No. INC-20 (Revocation/Surrender of License granted under Section 8)”
- Enter/search/select CIN
- Fill up the application, attaching the RD/Central Government order
- 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, after which a fresh COI is generated
Signing Requirements
- Digitally signed by an authorised signatory whose DIN/PAN/Membership number is registered on the MCA portal
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
Additional (Delay) Fee
Applicable for revocation ordered by the Central Government, computed from the date of the order; must be filed within 30 days.
| Period of Delay | Additional Fee |
|---|---|
| Up to 30 days | 2× normal fee |
| More than 30 up to 60 days | 4× normal fee |
No additional/delay fee applies to a voluntary surrender of license.
Processing Mode
Form INC-20 is processed in Non-STP mode — every filing is reviewed manually.
Useful Links
Frequently Asked Questions (FAQs)
Q1. What triggers the filing of INC-20? Either a Central Government order revoking a Section 8 company’s license, or a Regional Director order granting the company’s own request to surrender the license (applied for via INC-18).
Q2. What happens after INC-20 is registered? A fresh Certificate of Incorporation is issued, converting the company from a Section 8 company to any other kind of company, along with a change of name.
Q3. Is there a delay fee for both scenarios? No — the additional fee schedule applies to revocation ordered by the Central Government; voluntary surrender does not attract a delay fee.
Q4. Is INC-20 processed automatically? No, it is always processed in Non-STP mode with manual review.
Q5. What form is used to apply for voluntary surrender before INC-20? Form INC-18, filed with the Regional Director.
Disclaimer
This article is based on the official Instruction Kit for Form INC-20 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 forms download page and resources available on the MCA website.