♦ Introduction
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.
♦ Purpose
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
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