On July 19, 2024, the Institute of Company Secretaries of India (ICSI) addressed challenges faced by stakeholders using the MCA-21 V3 portal, which transitioned from MCA-21 V2 to enhance digital compliance under the Companies Act, 2013, and the LLP Act, 2008. The ICSI acknowledged the Ministry of Corporate Affairs’ efforts to improve ease of doing business but highlighted several issues, including difficulties with OTP generation for foreign nationals, incorrect prefilled data in forms, and problems with saving or submitting forms. Specific concerns include issues with forms DIR-3 KYC, PAS-3, INC-24, and CHG-1, as well as common problems such as login issues, outdated profile information, and excessive captcha usage. The ICSI recommended solutions like minimizing captcha usage, enabling data saving for incomplete forms, and ensuring timely approval of forms to streamline the compliance process. They requested prompt attention to these issues to support effective business operations and regulatory compliance.
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)
CL:MCA: July/2024 Dated: July 19, 2024
Shri Manoj Govil, LAS
Secretary
Ministry of Corporate Affairs
Government of India
Shastri Bhawan
New Delhi -110001
July 19, 2024
Subject: Functioning of MCA- 21 V3 Portal – Issues and Challenges facing stakeholders – Reg.
Respected Sir,
This has reference to the transition of the compliance operations of the Ministry of Corporate Affairs from MCA-21 V2 to MCA-21 V3 platform in an attempt to embrace digital transformation and furtherance of the agenda of the Government of India’s efforts to promote Ease of Doing Business (EODB) for the India Inc. An integral part of this transition has been the alteration in the filling, filing and processing of e-forms filed under the Companies Act, 2013 and the Limited Liability Partnership Act, 2008.
At the outset, as we commend the efforts of the Ministry to make the transition as smooth as possible — all in a phased manner; akin to every new initiative, issues and challenges are bound to creep in. We at the Institute of Company Secretaries of India are happy to partner with the Ministry in sharing these issues of the stakeholders as well as providing support wherever possible.
In this regard, we wish to bring to your kind notice that certain issues are being faced by the stakeholders while engaging with the MCA21-V3 platform for the purpose of filing of forms for, their companies and clients. Some of these issues/concerns/ technical glitches are placed below for your kind consideration and timely resolution:
SPECIFIC FORM RELATED ISSUES
| Form | Purpose | Issues / Challenges |
| DIR-3 KYC and DIR-3 Web KYC | Verify Director’s KYC details | Difficulty in generating OTPs in case of foreign nationals leading to non-compliance |
| PAS-3 | Return of Allotment of Securities
|
|
| INC-24 | Application for approval of Central Government for change of name |
|
| CHG-1 | Application for registration of creation, modification (other than those related to debentures) including particulars of modification of charge by Asset Reconstruction Company in terms of SARFAESI, 2002 | Unable to Recognise Registered DSC:
Even while DSC is well registered with the particular DIN, upon submission of the Form after affixing he DSC following error is occuring :
|
COMMON ISSUES AND CHALLENGES
| Login Issue: |
|
| Unmasking/unhiding particulars of form till it is filed and submitted: |
|
| Time bound Approval of Forms |
|
| Minimise use of Captcha |
|
| Option to Save data of Forms may be provided |
|
| Resubmission date to be made available |
|
In light of the ultimate goal of simplifying procedural requirements and make the nation business ready. we request you to kindly consider the aforesaid practical difficulties and provide for their early resolution.
We shall be pleased to provide any further information or clarification in this regard on hearing from your good self.
Thanking You.
Yours faithfully
(CS B. Narasimhan)
President
The Institute of Company Secretaries of India
