Summary: The Institute of Company Secretaries of India (ICSI), through its President CS Pawan G. Chandak, submitted a representation dated 28 August 2026 to Dr. Pallavi Jain Govil, Secretary, Ministry of Corporate Affairs, Government of India, seeking an expeditious and time-bound mechanism for refund of amounts paid in respect of rejected incorporation applications. The representation highlights practical difficulties faced by stakeholders where filing fees, registration charges and applicable stamp duty are paid through the MCA portal for incorporation of a Company/LLP, but the application is subsequently rejected because of procedural, documentation or technical deficiencies.
ICSI points out that although incorporation does not ultimately materialise in such cases, the amounts already paid remain blocked, creating an avoidable financial burden. Where deficiencies are curable and a fresh application requires the entire payment to be made again, applicants face duplication of costs despite no corresponding incorporation or registration having taken place.
The representation requests that the amount paid for incorporation of companies be refunded within a prescribed and reasonable period to provide relief to genuine applicants whose applications are rejected for genuine reasons. ICSI states that timely refunds would reduce financial hardship and repetitive payments, encourage prompt rectification and re-submission, reduce avoidable delays, and strengthen stakeholder confidence in the MCA21 system. It further submits that a transparent and time-bound refund mechanism would support the Government’s Ease of Doing Business and Ease of Compliance initiatives.
THE INSTITUTE OF Company Secretaries of India
IN PURSUIT OF PROFESSIONAL EXCELLENCE
Statutory body under an Act of Parliament
(Under the jurisdiction of Ministry of Corporate Affairs)
Pawan G. Chandak
PRESIDENT
G&CL: MCA: AUG:07/ 2026 August 28, 2026
Dr. Pallavi Jain Govil
Hon’ble Secretary
Ministry of Corporate Affairs
Government of India
Respected Madam,
Subject: Representation for expeditious refund of fees paid for rejected incorporation applications
Greetings from the Institute of Company Secretaries of India!
We wish to draw your kind attention to the practical difficulties being faced by stakeholders in respect of the filing fees, registration charges and applicable stamp duty paid through the MCA portal for incorporation of a Company/LLP, particularly where the incorporation application is rejected due to procedural, documentation or technical deficiencies.
In such cases, although the incorporation does not ultimately materialise, the fees and charges already paid remain blocked, resulting in avoidable financial burden on the applicants.
Where an application is rejected for curable procedural, documentation or technical deficiencies, requiring the applicant to make the entire payment afresh for a subsequent application result in duplication of costs despite no corresponding incorporation or registration having taken place.
ICSI Submission
In view of the above, we request you to kindly consider that the amount paid for incorporation of companies may be refunded within a prescribed and reasonable time period for providing relief to genuine applicants whose incorporation applications are rejected on genuine reasons.
Justification
Timely refund would provide a fair and practical remedy to genuine applicants, reduce unnecessary financial hardship and eliminate repetitive payments. It would also encourage applicants to rectify deficiencies and re-submit applications promptly, thereby reducing avoidable delays in the incorporation process.
Further, a transparent and time-bound mechanism for refund would enhance stakeholder confidence in the MCA21 system and further strengthen the Government’s Ease of Doing Business and Ease of Compliance initiatives.
We will be pleased to furnish any additional information/clarification required in this matter.
Thanking you,
Yours faithfully,
(CS Pawan G Chandak)
President
The Institute of Company Secretaries of India
