Skip to main content
✓ Updated for FY 2026-27incorporation

INC-20A Late Fees & Penalty Calculator (FY 2026-27) — Commencement of Business

Calculate statutory normal filing fees, 180-day incorporation due date, Table B late fee multipliers (2× to 12×), Section 10A(2) adjudication penalties, and Section 446B relief for Form INC-20A on MCA V3.

📅 Due: Within 180 calendar days from Certificate of Incorporation date
⚖️ Penalty: Table B Multipliers (2× to 12×) + Section 10A(2) Adjudication (₹50k Co + ₹1k/day per Officer)
📋 Under: Section 10A(1)(a), Companies Act, 2013 read with Rule 23A of Companies (Incorporation) Rules, 2014
⚡ Fast Statutory Summary • Section 10A & Rule 23A

Form INC-20A is the mandatory one-time declaration for commencement of business under Section 10A. It is due strictly within 180 calendar days from incorporation. Delayed filing attracts Table B portal late multipliers (2× to 12× base fee) PLUS statutory adjudication penalties under Section 10A(2) of ₹50,000 on the company and ₹1,000/day per officer (max ₹1,00,000 each), halved under Section 446B for Small Companies and Startups.

✓ Strict Due Date: 180 Days from Incorporation•✓ Table B Multipliers: 2× to 12× Normal Fee•✓ Section 446B: 50% Reduced Penalty•✗ CCFS-2026 Amnesty: EXCLUDED
Form INC-20A Master Engine • Section 10A & Rule 23A

Commencement of Business Due Date & Penalty Determinant

180-day incorporation deadline tracker, MCA21 V3 slab-based multiplier calculator, and Section 10A(2) statutory adjudication penalty simulator.

The 180-Day Incorporation RuleSection 10A(1)(a)

Day 0 is the registration date on Certificate of Incorporation.

Date of submitting declaration on MCA V3.

Statutory Due Date: 2026-12-06

Filing within the statutory 180-day window. No late fee or Section 10A(2) adjudication penalty applies.

₹
All directors are liable under Section 10A(2) unless a specific officer is charged.
Per-officer penalty: ₹1,000/day (max ₹1 Lakh each), or ₹500/day (max ₹50,000 each) under Section 446B.
Section 446B Lesser Penalty AssessmentSTANDARD PENALTIES

Section 446B halves both the company fine (₹25,000) and officer caps (₹500/day max ₹50,000 each). Relief must be disclosed in the upcoming Board Report.

ON-TIME COMPLIANCE
Delay Duration
0 Days
MCA21 Portal e-Challan Fee0× (No Additional Fee)
Base: ₹400 + Late: ₹0
₹400
Section 10A(2) Adjudication Exposure
Company Fine:₹0
Officers (2 Directors):₹0
Total Adjudicated:₹0
Total Compliance Financial Liability
Portal Fee + Adjudication Exposure₹400

Personal Liability: Penalties imposed on directors under Section 10A(2) must be paid from personal funds, not from company accounts.

CCFS-2026 Ineligible: The CCFS amnesty scheme applies to Sections 92 and 137 only. Section 10A defaults are strictly excluded.

Statutory Fee Matrices (Registration Offices and Fees Rules, 2014)

Dual fee model: Nominal share capital determines base fee under Table A (Item 5); calendar delay determines multiplier under Table B.

Table A (Item 5) — Base Filing Fee by Authorized Capital
Nominal Capital BracketBase Normal Fee
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 (₹1 Crore) or more₹600
Company without share capitalExempt from 10A
Table B — Additional Fee Multipliers on Delay
Period of Delay (After 180 Days)Additional Multiplier
On time (within 180 days)0× (No Additional Fee)
Up to 30 days late (Days 181–210)2× Normal Fee
31 to 60 days late (Days 211–240)4× Normal Fee
61 to 90 days late (Days 241–270)6× Normal Fee
91 to 180 days late (Days 271–360)10× Normal Fee
More than 180 days late (Day 361+)12× Normal Fee

📌Key Facts

  • Filed ByPrivate Limited Companies, Public Limited Companies, One Person Companies (OPC), Small Companies, DPIIT-Recognized Startups, Producer Companies
  • Due DateWithin 180 calendar days from Certificate of Incorporation date
  • Section ReferenceSection 10A(1)(a), Companies Act, 2013 read with Rule 23A of Companies (Incorporation) Rules, 2014
  • Concessional Fee Applies?Yes (OPC / Small Company)

📊Fee Schedule

Nominal Capital BracketNormal Filing Fee
Less than ₹1,00,000₹200
₹1,00,000 or more but less than ₹5,00,000₹300
₹5,00,000 or more but less than ₹25,00,000₹400
₹25,00,000 or more but less than ₹1 crore₹500
₹1 crore or more₹600
Company not having share capital₹200

What is INC-20A?

Form INC-20A is the statutory declaration for commencement of business required under Section 10A of the Companies Act, 2013 and Rule 23A of the Companies (Incorporation) Rules, 2014. Introduced by the Companies (Amendment) Ordinance, 2018 (effective 2 November 2018), it ensures that newly formed companies do not operate as hollow shell entities before subscribers fulfill their capital commitment.

Through this electronic filing on MCA21 V3, an authorized director solemnly declares that all MOA subscribers have paid the full value of shares agreed to be taken, verified by bank statements and certified by an independent practicing CA, CS, or CMA.

Who Must File INC-20A?

Every company registered under the Companies Act, 2013 having a share capital and incorporated on or after 2 November 2018 must file Form INC-20A. This includes:

  • Private Limited Companies
  • Public Limited Companies (Unlisted & Listed)
  • One Person Companies (OPCs) with share capital
  • Small Companies with share capital
  • DPIIT-Recognized Startup Companies
  • Producer Companies with share capital
  • Section 8 Companies with share capital

Exempted Entities: Companies incorporated before 2 November 2018, companies without share capital (guarantee companies), and LLPs are legally exempt.

INC-20A Due Date & Timeline

The statutory deadline is strictly 180 calendar days from the date of incorporation printed on the Certificate of Incorporation (CoI). Day 0 is the registration date. Unlike annual filings (AOC-4 or MGT-7), there is no fixed calendar date or financial year trigger—each company has its own independent 180-day deadline. Day 181 onwards constitutes statutory default under Section 10A(2).

Consequences of Late Filing INC-20A

Failure or delay in filing Form INC-20A triggers four cascading legal consequences:

  1. Operational Freeze (Section 10A(1)): The company cannot legally commence commercial operations or exercise borrowing powers. Pre-filing agreements are voidable.
  2. MCA21 Slab Late Fees (Table B): Escalating multipliers from 2× to 12× normal filing fees.
  3. Statutory Adjudication Penalties (Section 10A(2)): Flat ₹50,000 fine on the company plus ₹1,000/day per officer in default (max ₹1,00,000 each), payable from personal funds (halved under Section 446B for Small Companies/Startups).
  4. Strike-Off Risk (Section 10A(3) / 248(1)(c)): If delay exceeds 180 days, ROC may initiate name removal and entity dissolution.

📋 Table A: Normal Base Filing Fee Schedule (Item 5)

Statutory base fee payable upon filing Form INC-20A on MCA21 V3 portal based on authorized nominal share capital under the Companies (Registration Offices and Fees) Rules, 2014.

Nominal / Authorized Capital BracketNormal Base FeeStatutory Reference & Entity Coverage
Less than ₹1,00,000₹200Table A, Item 5, Fees Rules 2014
₹1,00,000 to ₹4,99,999₹300Table A, Item 5, Fees Rules 2014 (Standard OPC bracket)
₹5,00,000 to ₹24,99,999₹400Table A, Item 5, Fees Rules 2014 (Standard ₹10L Pvt Ltd)
₹25,00,000 to ₹99,99,999₹500Table A, Item 5, Fees Rules 2014
₹1,00,00,000 or more (≥ ₹1 Crore)₹600Table A, Item 5, Fees Rules 2014 (Maximum base tier)
Company not having share capitalExempt from Sec 10ASection 10A(1)(a) applies strictly to companies having share capital

⏱️ Table B: Additional Late Fee Multiplier Schedule (2× to 12×)

Unlike AOC-4 and MGT-7 (which charge flat ₹100/day), Form INC-20A late filing fees on MCA V3 are calculated as multipliers of the Table A normal fee under Item B of the Fees Rules.

Period of Delay Beyond 180 DaysTable B MultiplierFee on ₹10L Capital (Base ₹400)Fee on ₹1Cr Capital (Base ₹600)
Up to 30 Days Delay (Days 181 to 210)2× Normal Fee₹400 + ₹800 = ₹1,200₹600 + ₹1,200 = ₹1,800
31 to 60 Days Delay (Days 211 to 240)4× Normal Fee₹400 + ₹1,600 = ₹2,000₹600 + ₹2,400 = ₹3,000
61 to 90 Days Delay (Days 241 to 270)6× Normal Fee₹400 + ₹2,400 = ₹2,800₹600 + ₹3,600 = ₹4,200
91 to 180 Days Delay (Days 271 to 360)10× Normal Fee₹400 + ₹4,000 = ₹4,400₹600 + ₹6,000 = ₹6,600
Beyond 180 Days Delay (Day 361 onwards)12× Normal Fee₹400 + ₹4,800 = ₹5,200₹600 + ₹7,200 = ₹7,800

⚖️ Section 10A(2) Statutory Penalties vs Section 446B Relief Comparison

Adjudication penalties are distinct from MCA portal e-Challan fees. Directors must remit penalties from personal funds, NOT from corporate bank accounts.

Statutory Subject / OffenderStandard Penalty (Section 10A(2))Section 446B Reduced Penalty (Small Co / Startup)Payment Source & Disclosure
Company Liability₹50,000 flat fine₹25,000 (50% relief)Payable from company funds; board disclosure required
Each Officer in Default (Director)₹1,000/day (max ₹1,00,000 each)₹500/day (max ₹50,000 each)PERSONAL FUNDS ONLY (cannot use company funds)
Total for 2 Directors (42 Days Delay)₹50k + ₹84k = ₹1,34,000₹25k + ₹42k = ₹67,000Benchmark order: ROC Pune (Dec 2025)
Total for 3 Directors (100+ Days Delay)₹50k + ₹3,00,000 = ₹3,50,000₹25k + ₹1,50,000 = ₹1,75,000Benchmark order: ROC Bangalore (Jun 2026)

🛡️ Operational Freeze, Strike-Off Risk & Escalation Timeline

Statutory consequences under Section 10A(1), Section 10A(3), Section 248(1)(c), and Section 454(8).

Timeline PhaseStatutory StatusOperational & Borrowing PowersEnforcement Action Risk
Days 0 to 180 from CoIStatutory WindowCannot commence business until INC-20A filedFully compliant; normal filing fees apply
Day 181 to Day 360Statutory DefaultOPERATIONAL FREEZE: Contracts voidable; loans unauthorizedTable B multipliers (2x to 10x) + Section 10A(2) per-day fine active
Day 361+ (> 180 Days Delay)Strike-Off TriggerSevere default; corporate capacity frozenROC empowered to initiate strike-off & dissolve entity under Section 248(1)(c)
Day 90 Post Adjudication OrderSection 454(8) EscalationPenalties unpaid after 90 days of orderAdditional fine ₹25k–₹5L on company; up to 6 months imprisonment for directors

Fee Calculation Example

Scenario: Private Limited Company (Authorized Capital ₹10 Lakhs, 2 Directors) filing INC-20A 42 Days Late

  • Nominal Share Capital: ₹10,00,000 → Normal Base Fee (Table A, Item 5): ₹400
  • Days of Delay: 42 calendar days → Table B Slab (31 to 60 days): 4× Normal Fee
  • Additional Late Fee: 4 × ₹400 = ₹1,600
  • Total MCA21 Portal e-Challan: ₹400 + ₹1,600 = ₹2,000
  • Section 10A(2) Adjudication Exposure: ₹50,000 (Company) + (42 days × ₹1,000 × 2 Directors = ₹84,000) = ₹1,34,000 (Directors pay personally).
  • Combined Financial Exposure: ₹2,000 + ₹1,34,000 = ₹1,36,000.

Frequently Asked Questions

What is Form INC-20A and why is it mandatory?

Form INC-20A is a mandatory one-time statutory declaration filed under Section 10A of the Companies Act, 2013 confirming that every subscriber to the Memorandum of Association (MOA) has deposited the agreed subscription money into the company bank account, and registered office verification under Section 12(2) is complete. Without filing INC-20A, the company cannot legally commence commercial operations or exercise borrowing powers.

What is the statutory deadline for filing Form INC-20A?

Form INC-20A must be filed strictly within 180 calendar days from the date of incorporation printed on the Certificate of Incorporation (CoI). Unlike annual returns, this deadline is unique to each company and does not align with financial years. Day 181 onwards is a statutory default.

What are the MCA portal fees for filing Form INC-20A late?

Late filing on the MCA21 portal incurs slab-based additional fees under Table B of the Fees Rules, 2014: Up to 30 days late: 2× normal fee; 31 to 60 days: 4× normal fee; 61 to 90 days: 6× normal fee; 91 to 180 days: 10× normal fee; beyond 180 days: 12× normal fee. The normal base fee ranges from ₹200 to ₹600 depending on authorized capital.

What are the statutory adjudication penalties under Section 10A(2)?

Separate from the MCA portal fee, default under Section 10A(2) attracts a flat penalty of ₹50,000 on the company and ₹1,000 per day of continuing default on every officer in default (capped at ₹1,00,000 per officer). Directors must pay this penalty from personal funds.

How does Section 446B reduce INC-20A penalties for Small Companies and Startups?

Under Section 446B, eligible Small Companies (per Section 2(85)), One Person Companies (OPC), Producer Companies, and DPIIT-recognized Startups are granted a 50% statutory reduction: the company penalty is capped at ₹25,000, and officer penalties are ₹500 per day capped at ₹50,000 per officer. This must be disclosed in the upcoming Board Report.

What happens if a company commences business or borrows loans before filing INC-20A?

Under Section 10A(1), commencing business or borrowing prior to filing is ultra vires and unlawful. Pre-filing loans are unauthorized, commercial agreements may be deemed voidable by counterparties, and directors face severe adjudication and prosecution risks.

Can the ROC strike off a company for not filing Form INC-20A?

Yes. Under Section 10A(3) read with Section 248(1)(c), if a company fails to file Form INC-20A within 180 days and the ROC has reasonable cause to believe no business is being carried on, the ROC may initiate strike-off proceedings and dissolve the corporate entity.

Is Form INC-20A covered under the CCFS-2026 amnesty scheme?

No. The Companies Compliance Facilitation Scheme (CCFS-2026) covers annual defaults under Sections 92 and 137 only. Section 10A defaults are strictly excluded from CCFS amnesty, meaning companies with pending INC-20A face the full Table B late fees and Section 10A(2) penalties.

Which companies are exempt from filing Form INC-20A?

Companies incorporated prior to 2 November 2018 (when Section 10A was introduced), companies without share capital (limited by guarantee without share capital), and LLPs are completely exempt from Form INC-20A.

What documents are mandatory for filing Form INC-20A on MCA V3?

Mandatory attachments include: (1) Corporate bank account statement showing individual subscription receipts from each subscriber, (2) Geo-tagged photographs of the registered office (external nameplate with CIN + interior with director), (3) Board Resolution under Section 179 authorising the director to sign, and (4) Digital certification by a practicing CA, CS, or CMA.

Often filed together with:

SPICe+— Incorporation of Company (SPICe+ / Form INC-32)AOC-4— Financial StatementsMGT-7— Annual Return

Other calculators:

LLP Penalty Calculator →MSME Interest Calculator →

Need to calculate for a different company form?

View All Company Calculators