PAS-6 — Reconciliation of Share Capital Audit Report (Half-yearly) Fee & Penalty Calculator (2026-27)

Form PAS-6 is the statutory Reconciliation of Share Capital Audit Report (Half-yearly) prescribed by the Ministry of Corporate Affairs under Section 29 of the Companies Act, 2013 read with Rule 9A (for unlisted public companies) and Rule 9B (for non-small private companies) of the Companies (Prospectus and Allotment of Securities) Rules, 2014.

Its primary objective is to maintain complete transparency over corporate equity by reconciling a company's total issued share capital against shares held in dematerialised electronic form with the two national depositories—National Securities Depository Limited (NSDL) and Central Depository Services (India) Limited (CDSL)—and physical share certificates. Any discrepancy between issued capital and depository records must be reported immediately to depositories under Rule 9A(8A).

The obligation to file Form PAS-6 applies on an ongoing half-yearly basis to:

• Unlisted Public Companies: Governed by Rule 9A since October 2018.
• Private Limited Companies (Non-Small): Governed by Rule 9B. All private companies that exceed the Small Company limits (paid-up capital > ₹10 Crore or turnover > ₹100 Crore per G.S.R. 880(E)) must obtain ISIN and file PAS-6.
• Private Holding & Subsidiary Companies: Disqualified from small company status under the proviso to Section 2(85); mandatory demat applies regardless of capital size.
• Section 8 Companies with Share Capital: Also excluded from small company classification under Section 2(85).
• Producer Companies: Required to comply by 31 March 2028 per the February 2025 amendment.

Exempt Entities: Small Companies under Section 2(85), Listed companies (covered under SEBI Regulation 55A), Nidhi companies, Government companies, and Wholly-Owned Subsidiaries of unlisted public companies are exempt.

Form PAS-6 is filed semi-annually within 60 calendar days from the conclusion of each half-year:

• Half-Year 1 (1 April to 30 September): Due on or before 29th November.
• Half-Year 2 (1 October to 31 March): Due on or before 30th May.

A separate Form PAS-6 must be submitted electronically on MCA V3 for each individual ISIN (e.g., if a company has both equity shares and preference shares, two distinct PAS-6 filings are required per half-year).

Delayed or non-filing of Form PAS-6 triggers dual statutory liabilities:

1. MCA21 Portal Additional Fee (Table B Multiplier): The portal automatically levies an additional fee scaling from 2× to 12× the normal filing fee depending on the duration of delay past the 60-day window (12× maximum fee of up to ₹7,200 for delay exceeding 180 days).
2. Section 450 Civil Adjudication Exposure: Under Section 450 read with Section 454, the ROC may initiate adjudication proceedings imposing a base penalty of ₹10,000 plus ₹1,000 per day of continuing default on the company (capped at ₹2,00,000) and ₹10,000 plus ₹1,000 per day on each officer in default (capped at ₹50,000 per officer). Section 446B halves these penalties for eligible startups.
3. Commercial Embargo (Rule 9A(4) & 9B(4)): Companies in default cannot issue bonus shares, rights issues, private placements, or buybacks. Non-compliance severely impairs investor due diligence in M&A and funding rounds.