PAS-6 Reconciliation of Share capital Audit Report (Half yearly basis and its applicability)


As per sub rule 8 of Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014, company every unlisted public company governed by this rule shall submit Form PAS-6 to the Registrar with such fee as provided in Companies (Registration Offices and Fees) Rules, 2014 within sixty days from the conclusion of each half year duly certified by a company secretary in practice or chartered accountant in practice. 

Highlights of Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014

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

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

3. Every securities holder of 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 company under this rule shall be filed before the IEPF Authority.


The rule shall not be applicable to following classes of unlisted public company:

1. A Nidhi Company

2. A Government Company

3. A wholly owned subsidiary Company

Due date of filing of e-form PAS-6

As per General Circular No. 16/2019 dated 28th November, 2019, the time limit for filing of Form PAS-6 without additional fees for the half year ended on 30.09.2019 will be sixty days  from the date of deployment of this form on the website of the Company.

The E-form PAS-6 was available for filing on MCA website from 15th July, 2020. The due date of filing of e-from PAS-6 will be 12th September, 2019 as interpreted from this circular.

Further, the due date of e-form PAS-6 is falling under moratorium period starting from 01.04.2020 to 30.09.2020 given by MCA vide General Circular dated 24th March, 2020 (special measures taken in view of COVID-19 outbreak).

Therefore, Companies can file e-form PAS-6 till 30th September, 2020 without any additional fees for half year ended on 30.09.2019 and 31.03.2020.

Link to the circular:

Requirements of filing of PAS-3

1. ISIN of each Securities

2. Period of Filing such as 1st October to 31st March or 1st April to 30th September

3. Details of Capital of the Company

    Number of Shares Percentage of Total Issued Capital
a Issued Capital
b Held in dematerialised form in CDSL
c Held in dematerialised form in NSDL
d Held in physical form
e Total No. of Shares (b)+ (c)+(d)

4. Reason of differences in  (a) and (e)

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

Private Placement
Amalgamation Conversion
Buy back
Capital Reduction
Any other (Please  Specify)

6. Details of Shares held by Promoters, Directors, and KMPs

7. Information about register of members updated or not

8. Information about dematerialised shares in excess in the previous half-yearly period

9. Particulars about 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:

10. Particulars about the Company Secretary of the Company if any

11. Certification from CA/CS

Relevant FAQ

Q 1. Whether ISIN is compulsory for filing of PAS-6?

Ans. ISIN is compulsory for filing of PAS-6 as evident from Point No.3 of the from the e-form  PAS-6. The e-form PAS-6 shall be filed for each ISIN of securities.

Q 2. What is the penal provision for not obtaining ISIN?

Ans. As there is no penalty prescribed under rule 9A for non-compliance, therefore section 450 (punishment where no specific penalty or punishment is provided) will be applicable.

As per Section 450, 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.

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April 2021