The Institute of Company Secretaries of India (ICSI), through its President CS Pawan G. Chandak, has followed up with the Ministry of Corporate Affairs on various representations submitted regarding practical difficulties faced by stakeholders, ease of compliance and improvement of the MCA-21 system. The representations cover amendment of Rule 8A of the Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014; compliance relating to appointment of Whole-time Company Secretaries; setting up NCLT Benches at Pune and Patna of the Companies Act, 2013 and Section 59 of the IBC; an amnesty or condonation mechanism for delayed BEN Forms; Regional Director notices and Section 12(8); shifting of registered office within the same State; e-filing processing; Section 14(1); MGT-8 format; conversion under Section 366; compliance mechanisms for small companies; and Secretarial Audit for bigger companies. ICSI requested the Ministry to review the representations and facilitate early resolution of the issues in the interest of stakeholders and ease of doing business.
Institute of Company Secretaries of India
CS Pawan G. Chandak
PRESIDENT
G&CL: MCA: AUG:02 / 2026 | Dated: August 20, 2026
Dr. Pallavi Jain Govil
Hon’ble Secretary
Ministry of Corporate Affairs
Government of India
Respected Madam,
Subject: Follow-up on representations submitted by ICSI on various matters
Greetings from the Institute of Company Secretaries of India!
The ICSI has submitted various representations to the Ministry from time to time, highlighting practical difficulties faced by stakeholders and suggesting measures to facilitate ease of compliance and improve the MCA-21 system.
In continuation thereof, the Institute respectfully requests you to kindly consider the representations listed below:
| S. No. | Subject of Representation | Date of Submission | Annexure |
|---|---|---|---|
| 1. | Representation for amendment of Rule 8A of Companies (Appointment and Remuneration of Managerial Personnel) Rules, 2014 | 20th July 2026 | I |
| 2. | Representation regarding ensuring compliance with the provisions relating to appointment of Whole-time Company Secretaries by eligible companies | 19th June 2026 | II |
| 3. | Request to facilitate setting up of a Bench of NCLT at Pune, Maharashtra | 4th May 2026 | III |
| 4. | Clarification regarding applicability of e-Form ADT-1 for:
|
16th April 2026 | IV |
| 5. | Request for permitting filing of Forms during liquidation process | V | |
| 6. | Allowing Change / Modification in the Name of Trusts Registered for Receiving CSR Funds | 30th March 2026 | VI |
| 7. | Prioritized listing of matters u/S 230-232 & 252 of Companies Act, 2013 and Sections 59 under IBC at various Benches of Hon’ble NCLT | VII | |
| 8. | Request for Introduction of Amnesty Scheme / Condonation for Delay in Filing of BEN Forms under the Companies Act, 2013 | 18th March 2026 | VIII |
| 9. | Issuance of notices by Regional Directors and application of Section 12(8) – Request for adherence to principles of natural justice | 16th March 2026 | IX |
| 10. | Exempt companies from RD approval for shifting of RO within same state on account of establishment of new ROC’s within same state | X | |
| 11. | Issuance of instructions to RDs/ROCs for processing applications filed through E Filing without mandatory physical submission | XI | |
| 12. | Modification in first proviso to Section 14(1) regarding effective date of conversion of private company into public company | XII | |
| 13. | Request for modification in layout of e-form MGT-8 | 6th June 2025 and 1st September, 2025 | XIII |
| 14. | Request for Establishment of NCLT Bench at Patna, Bihar | 5th March 2025 & 7th August 2025 | XIV |
| 15. | Request for modification in format of Certificate of Incorporation in the case of conversion of an entity into Company under section 366 of Companies Act, 2013 | 6th June 2025 | XV |
| 16. | Introduction of Compliance Mechanism to Promote Governance in Small Companies | 3rd March 2025 | XVI |
| 17. | Secretarial Audit for Bigger Companies | 26th August 2020 | XVII |
We shall be grateful if the Ministry may kindly review the above representations and facilitate early resolution of the issues in the interest of stakeholders and ease of doing business.
The Institute appreciates the continued support and responsiveness of the Ministry towards stakeholder concerns.
We will be pleased to furnish any additional information/clarification required in this matter.
Thanking you,
Yours faithfully,
(CS Pawan G Chandak)
President
The Institute of Company Secretaries of India
