(Reconciliation of Share Capital Audit Report on half yearly basis)


Reconciliation of Share capital Audit Report on half yearly basis by unlisted public Companies.

Legal Provision: 

Ministry of Corporate Affairs (MCA) vide its notification dated 10th September 2018, inserted Rule 9A of Companies (Prospectus and Allotment of Securities), Rules, 2014, for Issue of securities in dematerialized form by unlisted public companies which is effective from 02nd October 2018.

Rule 9A:

Issue of securities in dematerialized form by unlisted public companies. It states as every unlisted public company shall –

1. Issue the securities only in dematerialized form; and

2. Facilitate dematerialization of all its existing securities

In accordance with provisions of the Depositories Act, 1996 and regulations made there under.

Features of Rule 9A:

1. Every unlisted public company shall issue the securities only in dematerialized form and facilitate the dematerialization of all its existing securities (obtain ISIN for each type of security).

2. Before making any offer for the issue of any securities by the unlisted public company, the entire holding of securities of its promoters, directors, KMP is in Demat form.

3. Every securities holder of an unlisted public company shall get his securities in Demat form before transferring to any person or subscribing to any issue of securities.

4. Submission of reconciliation of share capital audit report.

5. The Grievances of security holders of unlisted public companies under this rule shall be filed before the IEPF Authority.

Applicable On:

1. Unlisted Public Companies or

2. Deemed Public Companies (a Private Company which is a subsidiary of Public Company).

Every unlisted public company governed by this rule shall submit Form PAS-6 to the Registrar of companies with such fee as provided in Companies (Registration Offices and Fees) Rules, 2014 within 60 days from the conclusion of each half year.


This rule shall not applicable to an unlisted public company which is:

1. A Nidhi;

2. A Government company or

3. A wholly owned subsidiary.

Period of reporting after deployment of form PAS-6:

Companies have to file 2 PAS-6 for each category of securities

1. One for the period 01/04/2019 to 30/09/2019

2. Second for the period of 01/10/2019 to 31/03/2020

Due date for the filing of PAS-6:

The last date for filing of PAS-6 after deployment of form PAS-6 is 12th September 2020 and thereafter 60 days from the date of the conclusion of each half year.

Different categories of Securities:

If a company has a different type of securities i.e. Equity, Preference, Debentures, etc. in this case company has to obtain different ISIN and has to file different PAS-6 for each category of securities.

Company has not dematerialized its shares by 31st March 2020:

If the company did not dematerialize its shares by 31st March 2020 in such a case the company has to fill share details in shares “held in physical form” Column.

Attach any documents in PAS-6:

No, there is no need to attach anything in the form.

Content of E-form:

1. Corporate identity number (CI.N) of company:

(a) Name of the Company:

(b) Address .of the registered office:

(c) E-mail id, if any:

(d) Phone Number:

2. ISIN:

3. Period of filing: From:

4. Details of the capital of the company:

5. Reasons for difference in 5(a) and 5(e) 7:

6. Details of changes in share capital during the half-year under consideration as per Table:

7. Details of shares held by:

    • Promoter;
    • Director;
    • Key Managerial Personal;

8. (a) Whether the Register of Members is updated:

(b) If not, the date upto which it has been updated:

9. Whether there were dematerialized shares in excess in the previous half-yearly period:

10. Has the company resolved the matter mentioned in point no. 10 above in the Current half- year:

If not, reason why

11. Mention the total no. of demat requests, if any, confirmed after 21 days and the total no. of demat requests pending beyond 21 days with the reasons for delay:

12. Name, Address, E-mail and Telephone No. of the Company Secretary of the Company, if any:

13. Name, Address, E-mail, Telephone No. and Registration. No. of the CA/CS certifying this form:

14. Whether there is appointment of common agency for share registry work:

If yes (Name & Address):

16. Any other detail that the professional signing this form may like to provide:

Penal provision for not obtaining ISIN: 

As there is no penalty prescribed under rule 9A for non-compliance, therefore U/s 450 of the companies act,2013 punishment where no specific penalty or punishment is provide will be applicable. The company and every officer of the company who is in default or such other person shall be punishable with fine which may extend to ten thousand rupees, and where the contravention is continuing one with a further fine which may extend to one thousand rupees for every day after the first during which the contravention continues.

DISCLAIMER: The information given in this document has been made on the basis of the provisions of the Companies Act, 2013 and Rules made thereunder.Under no circumstances whatsoever, we are not responsible for any loss, claim, liability, damage(s) resulting from the use, omission or inability to use the information provided in the document.

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  1. Brajesh Kumar says:

    Dear Sir,

    Due date is 30.09.2020 for both half year ended 30.09.2019 and 31.03.2020. For more details see my article on PAS-6.

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