Summary: The Institute of Company Secretaries of India (ICSI), through a letter dated October 28, 2026, addressed to Dr. Pallavi Jain Govil, Secretary, Ministry of Corporate Affairs, Government of India, has requested the Ministry to review and consider representations previously submitted on practical difficulties faced by stakeholders. The representations seek to facilitate ease of compliance and improve the MCA-21 system. The five matters listed include recognition of the concept of deemed government companies under the Companies Act, 2013; non-functionality of the registration process on the E-SAHAJ SEWA Portal; expeditious refund of fees paid for rejected incorporation applications; introduction of a separate e-Form for filing the appointment and resignation of Secretarial Auditors under Section 204 of the Companies Act, 2013; and authorisation of Company Secretaries in Practice to represent parties before authorities under the Partnership Act, 1932. ICSI has also requested consideration of earlier representations referred to in its letter dated August 20, 2026. The Institute has urged the Ministry to review these matters in the interest of stakeholders and ease of doing business, and has offered to provide any additional information or clarification required.
THE INSTITUTE OF COMPANY SECRETARIES OF INDIA
G&CL: MCA: OCT:03/2026 Dated: October 28, 2026
Dr. Pallavi Jain Govil
Secretary
Ministry of Corporate Affairs
Government of India
Respected Madam,
Subject: Follow-up on representations submitted by ICSI on various matters
Greetings from the Institute of Company Secretaries of India!
The ICSI has submitted various representations to the Ministry from time to time, highlighting practical difficulties faced by stakeholders and suggesting measures to facilitate ease of compliance and improve the MCA-21 system.
In continuation thereof, the Institute respectfully requests you to kindly consider the representations already submitted, details of which are listed below for ready reference:
| S. No. | Subject of Representation | Date of Submission | Annexure |
|---|---|---|---|
| 1. | Representation for recognition of the concept of ‘Deemed Government Companies‘ under the Companies Act, 2013 | 28th August 2026 | I |
| 2. | Representation regarding non-functionality of the registration process on the E-SAHAJ SEWA Portal | — | II |
| 3. | Representation for expeditious refund of fees paid for rejected incorporation applications | — | III |
| 4. | Representation for Introduction of a separate e-Form for filing appointment and resignation of Secretarial Auditor appointed under Section 204 of the Companies Act, 2013 | — | IV |
| 5. | Representation for Authorising Company Secretary in Practice to Represent Parties before Authorities under the Partnership Act, 1932 | 23rd September 2026 | V |
Further in reference to ICSI letter No. GaCl: MCA: AUG:02/2026 dated August 20, 2026, we request you to kindly consider the representations submitted in past as well along with aforesaid submitted representations. (Copy of letter enclosed as Annexure VI.).
We shall be grateful if the Ministry may kindly review the above representations and favourably consider the same in the interest of stakeholders and ease of doing business.
The Institute appreciates the continued support and responsiveness of the Ministry towards stakeholder concerns.
We will be pleased to furnish any additional information/clarification required in this matter.
Thanking you,
(S Pawan G Chandak)
President
The Institute of Company Secretaries of India
