Form PAS-6: Reconciliation of Share Capital Audit Report (Half- yearly)- Penalties & Highlights

Every unlisted public company governed by the rules shall submit this form to the Registrar within sixty days from the conclusion of each half year duly certified by a Company Secretary in practice or Chartered Accountant in practice.

It is a Reconciliation of Share Capital Audit Report that depicts Physical shares, Demat shares, Total issued capital and reconciliation with depository records.

Governing Law:

• Section 29 of Companies Act, 2013 –
• Pursuant to Sub Rule 8 of Rule 9A and 9B of The Companies (Prospectus and Allotment of Securities) Rules, 2014.
• MCA notification dated 10th September 2018
• MCA Notification dated 27th October 2023
• MCA Notification dated 12th February 2025

Applicability:

1. Unlisted Public Company after obtaining ISIN

2. Private Company (Not Small) after obtaining ISIN

In short, the form filing is mandatory when the Company has obtained an ISIN and where Rule 9A and Rule 9B of The Companies (Prospectus and Allotment of Securities) Rules, 2014 is applicable.

It is pertinent to note that even if zero shares are dematerialised, PAS-6 must be filed once ISIN is obtained.

The said rule is not applicable to an unlisted public company which is:-

a) a Nidhi;

(b) a Government company or

(c) a wholly owned subsidiary.

As per Rule 9A (8): The Form PAS-6 – Reconciliation of Share Capital Audit Report is to be filed every half year within 60 days from the end of half year. The due date for half year ended March 2026 is 30^th May, 2026 and for half year ended September 2026 is 29^th November, 2026.

Key Highlight of E-Form PAS-6:

1. All information shall be furnished for the half year ended 30^th September and 31^st March in every half financial year for each ISIN separately

2. Mention ISIN of each type of security

3. Details of capital of company:

• • Issued Capital
  • Held in dematerialized form in CDSL
  • Held in dematerialized form in NSDL
  • Held in Physical form
  • Reason for any difference in Issued & Total Capital

4. Details of the total shares held by directors, promoters and KMP in physical and Demat form.

5. Details of changes in share capital during the half-year under consideration.

6. Detail regarding Updating of Register of Members.

7. 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 reasons for delay.

8. Details of Company Secretary of the Company, if any and name of Registrar and Share Transfer    Agent.

9. Details of CA/CS certifying this form.

Penalties for Non-Compliance:

As per Section 450 of the Companies Act, 2013: Company and every officer in default:

• ₹10,000 and
• ₹1,000 per day for continuing default
  (Maximum: ₹2,00,000 for company and ₹50,000 for officer)