Revised MGT-7: Mandatory Shareholder Details & Validation

MGT-7: A New Era of Shareholder Compliance and Data Extraction: Most Imp: Any deviation from the Validation Sheet

Yes, There is deviation from Validaiton Sheet. Will discuss in detail in this article.

The Ministry of Corporate Affairs (MCA) is set to launch the revised MGT-7 form for the financial year ending March 31, 2025, on the MCA V3 portal. This update introduces significant changes aimed at enhancing the filing process, improving data accuracy, and streamlining compliance for companies.

We have been receiving numerous queries from professionals and corporates across the country regarding the revised MGT-7 form, particularly concerning whether it is mandatory to mention details such as the PAN and folio number of shareholders. In this article, we will address these common concerns and clarify the mandatory fields for shareholder information in the new form. We will provide insights into which data points are required for compliance and explain how these changes impact the filing process, ensuring that companies can meet the updated regulatory requirements with confidence.

As we know there are two ways to file MGT 7 i.e. Offline and Online. What excels we have to fille in both scenarios:

Offline Mode: In case of offline mode following excels needs to fill:

• Complete form MGT 7
• List of Shareholders.

Online Mode: In case of online mode following excels needs to fill:

• List of Shareholders
• Details of Board meeting/ committee Meeting
• Details of Holding and Subsidiary (if any)
• List of Transfer of Shares

Main and important question is relating to List of Shareholder like:

i. Whether it is mandatory to attached signed pdf of list of shareholders? OR Is it mandatory to attach the signed PDF of the shareholder list with MGT-7?

ii. Whether it is mandatory to fill shareholder information in the validation sheet provided by the form? OR Can the shareholder list in MGT-7 be prepared using an external Excel sheet?

iii. Whether we can prepare shareholder list in our own excel and use for all Companies?

iv. Whether PAN and Folio No of shareholder is mandatory? OR Is it mandatory to mention the PAN of shareholders in MGT-7?

Question 1: Whether it is mandatory to attach a signed PDF of the list of shareholders?

As per the revised guidelines for MGT-7 under the MCA V3 portal, it is not mandatory to attach a signed PDF of the list of shareholders. However, the list must be accurately compiled and included in the form, with all necessary shareholder details in excel.

Question 2: Whether it is mandatory to fill shareholder information in the validation sheet provided by the form?

Yes, it is mandatory to fill in the shareholder information in the validation sheet provided by the MGT-7 form. The validation sheet serves as a critical tool to ensure that all shareholder details are captured accurately and in the correct format. Failure to complete this sheet may result in errors during the filing process or non-compliance with regulatory requirements.

However, there is one deviation in the validation sheet process. When downloading the Excel file from the MCA portal while preparing the MGT-7, two sheets will appear:

1. Sheet One: This sheet contains the list of shareholders along with the validation details. This is where the mandatory shareholder information must be filled, ensuring that it complies with the required format and validation checks.

2. Sheet Two: This sheet does not have any validation requirements, allowing companies to enter additional shareholder details at their discretion, based on their internal record-keeping or any supplementary information that is not mandated for the filing.

While Sheet One is required to ensure compliance with the prescribed format, Sheet Two offers flexibility for the company to add more data that may be relevant but not mandatory for the statutory filing.

Question 3: Whether we can prepare shareholder list in our own excel and use for all Companies?

It is not allowed to prepare the shareholder list in your own Excel and use it across multiple companies. The MCA sheet is software-based and is specifically linked to the unique SRN (Service Request Number) generated for each MGT-7 filing.

The list of shareholders must be filled in the validation sheet provided within the MCA’s downloadable Excel, as it is tailored to the MGT-7 form being filed. The data in this sheet is directly linked to the specific SRN and cannot be reused or substituted across different companies. Any attempt to use an external Excel sheet that does not adhere to the MCA format will likely result in errors during the filing process.

Question 4: Whether PAN of shareholder and Folio number of shareholder is mandatory in MGT-7 on MCA V3?

Yes, both the PAN and Folio number of shareholders are mandatory in the revised MGT-7 form on the MCA V3 portal. These details are essential for ensuring accurate identification and verification of shareholders. The PAN serves as a unique identifier for individuals and entities, while the Folio number is crucial for tracking shareholding in physical form, especially for companies that still have physical share certificates.

Failure to provide these details may lead to non-compliance and errors in the filing process, so it is important to include both PAN and Folio number for each shareholder as required.

Question 5: What information is required under the shareholder list section of MGT-7?

Answer: The shareholder list section of MGT-7 requires information such as:

• Name of the shareholder
• PAN of the shareholder (for individuals and entities)
• Folio number (for physical shareholders)
• Shareholding details (number of shares held)
• Category of shareholders (e.g., promoter, public, etc.)

Conclusion

The revised MGT-7 form under the MCA V3 portal marks a significant step towards enhancing the efficiency and accuracy of shareholder compliance and data extraction for companies. With mandatory fields like PAN and Folio numbers, as well as the requirement to use the MCA-provided validation sheet, companies must adhere to these updated filing procedures to ensure smooth and compliant submissions. While there is flexibility in the process, such as the ability to add additional shareholder details in the non-validation sheet, it is crucial to follow the prescribed formats to avoid errors and non­compliance.

By understanding the nuances of the new MGT-7, including the mandatory fields and the importance of the validation sheet, companies can ensure that they meet all regulatory requirements efficiently and accurately. As we move into this new era of compliance, staying informed about these updates will empower businesses to navigate the filing process seamlessly and with confidence.

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Author – CS Divesh Goyal, GOYAL DIVESH & ASSOCIATES Company Secretary in Practice from Delhi and can be contacted at csdiveshgoyal@gmail.com).