Initially, reconciliation of Share Capital Audit Report was applicable only for Listed Companies and was required to be filed with Stock Exchanges on a quarterly basis as per SEBI (Depositories and Participants) Regulations.

Now, Central Government (Ministry of Corporate Affairs) has introduced a similar concept  under the Companies Act, 2013 for unlisted public companies. Form PAS-6 was introduced vide Companies (Prospectus and Allotment of Securities)Third Amendment Rules, 2019 published on 22nd May, 2019 which was effective from 30th September, 2019. However, e-form PAS-6 was deployed on the MCA portal only on 15th July, 2020.

Legal Provisions

S.29 (1A) of the Companies Act 2013 and Rule 9A (8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014.


Form PAS-6 is a half yearly audit report on reconciliation of share capital which is to be certified by a Company Secretary in practice or a Chartered Accountant in practice.

Due Date:

  • E-form PAS-6 shall be filed with ROC for each ISIN separately
  • It shall be filed within 60 days from the end of each half yeare.
  • On or before 12th September 2020 for half year ended 30th September 2019 & also for 31st March 2020 and thereafter within 60 days from end of each half year.

Applicability of Form PAS-6:

Applicable to every Unlisted Public Company (except  Nidhi Company;  Government company or wholly owned subsidiary)

Key Details to be inserted within the Form PAS-6:

  • ISIN & Details of Capital of the Company (held in dematerialised form in CDSL, NSDL and shares held in physical form) along with reason for any differences
  • Details of changes in the share capital in the form of Rights, Bonus, Private placement, ESOPs, Amalgamation, Conversion, Buyback, Capital Reduction, Forfeiture and others
  • Details of shares held by Promoters, Directors and KMP
  • Details of number of demat requests, number of shares and reasons for delay for requests confirmed after 21 days or requests pending beyond 21 days

Author Bio

Qualification: CS
Company: A. M. Sheth & Associates, Practising Company Secretaries
Location: Mumbai, Maharashtra, IN
Member Since: 31 Jul 2020 | Total Posts: 3

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May 2021