The Ministry of Corporate Affairs (MCA), via GSR 426(E) dated 27th June 2025, introduced a revised Form INC-22A (ACTIVE) under the Companies (Incorporation) Amendment Rules, 2025. This new e-form is set to come into force on 14th July 2025 and replaces the previous version of Form INC-22A. However, a key question arises: Which companies are required to file this revised form?
This article aims to clarify the applicability of Form INC-22A, the legal context, and the impact of the new amendment.
Background: What is Form INC-22A (ACTIVE)?
Form INC-22A, titled “ACTIVE – Active Company Tagging Identities and Verification,” was introduced to verify and update essential company details, such as:
- Registered office address
- Email ID verification via OTP
- Director and KMP details
- Auditor and cost auditor information
- Photograph of registered office with a Director/KMP
It was first notified via GSR 144(E) dated 21st February 2019, under Rule 25A of the Companies (Incorporation) Rules, 2014.
Applicability as per Original Rule 25A
As per Rule 25A(1), originally introduced in 2019:
“Every company incorporated on or before the 31st December, 2017 shall file the particulars of the company and its registered office in e-Form ACTIVE (INC-22A)”.
This provision was applicable to all companies except:
- Companies struck off or under the process of striking off
- Companies under liquidation, amalgamation, or dormant status
- Companies where directors’ DINs are not in “approved” status
The 2025 Amendment: What Changed?
The recent GSR 426(E) notification (27 June 2025) does not amend Rule 25A itself. Instead, it simply replaces the existing e-form INC-22A with a new format, updating its structure and information requirements. Key changes include enhanced verification of:
- Auditor and cost auditor details
- Financial year coverage
- Photograph showing both the external and internal views of the registered office with a signatory Director/KMP
- Additional professional certification requirements
But what about applicability?
Contrary to some interpretations, the 2025 amendment does not change the applicability date of Form INC-22A. That is, it does not introduce a new cut-off like “companies incorporated on or before 31st March 2025.”
As of now, Rule 25A still applies only to companies incorporated on or before 31st December 2017, unless MCA notifies otherwise.
Conclusion
As it stands:
- The revised Form INC-22A (ACTIVE) comes into effect on 14th July 2025.
- It applies only to companies incorporated on or before 31st December 2017, as per existing Rule 25A.
Any extension or change in applicability (e.g., up to 31st March 2025) will require a fresh MCA notification or rule amendment, which has not yet been issued.
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