FORM PAS-6 Due on 29th November 2025 – A Complete Guide for Companies


Compliance under the Ministry of Corporate Affairs (MCA) continues to evolve, ensuring transparency, accountability, and security in the corporate ecosystem. One such essential compliance requirement for many companies is Form PAS-6, the Reconciliation of Share Capital Audit Report. As we approach the crucial deadline of 29th November 2025, companies that fall under the filing criteria must ensure timely submission for the half-year ending 30th September 2025.

Whether you are a director, company secretary, or compliance officer, understanding PAS-6 is essential for staying compliant and avoiding penalties. This blog provides a complete, easy-to-understand breakdown of Form PAS-6, its requirements, exemptions, and key compliance tips.


What is Form PAS-6?

Form PAS-6 is a half-yearly report that must be filed with the Registrar of Companies (ROC) to reconcile the issued and actual share capital of a company. It ensures that:

  • The securities of the company are held in dematerialized form,

  • The share capital records at the depository match those maintained by the company, and

  • There are no discrepancies in the issued, subscribed, or paid-up capital.

This form is part of the government’s push toward complete dematerialization and enhanced corporate governance.


Who Must File Form PAS-6?

Form PAS-6 is applicable to several types of companies. If your company falls in any of the following categories, filing PAS-6 is mandatory:

Unlisted Public Companies

All unlisted public companies, regardless of size or turnover, must comply with PAS-6.

Certain Private Companies

Some private companies fall under the dematerialization mandate, including:

  • Companies meeting specific paid-up share capital thresholds

  • Companies with high turnover, or

  • Those that have defaulted on certain statutory requirements

These companies are required to issue and transfer securities only in demat form, making PAS-6 a compulsory filing.

Section 8 Companies (Non-small classification)

Section 8 companies not classified as small companies must also file PAS-6.


Exemptions from PAS-6 Filing

Not all companies are required to file Form PAS-6. The following categories are exempt:

Nidhi Companies

As special financial entities regulated by separate rules, they are excluded.

Government Companies

Companies owned/controlled by the government have their own compliance framework.

Wholly-Owned Subsidiaries of Unlisted Public Companies

These subsidiaries are not required to file PAS-6 even though their parent companies may fall under other compliance rules.

Small Private Companies

Private companies classified as “small” under the Companies Act enjoy exemption from PAS-6.

If your company falls into one of these categories, PAS-6 filing is not applicable for this cycle.


Prerequisites for Filing PAS-6

Before attempting to file the PAS-6, ensure the following conditions are fulfilled:

πŸ”Ή All Securities Must Be in Demat Form

This is the foundation of PAS-6 compliance. Any pending physical shares held by promoters, directors, or shareholders must be dematerialized immediately.

πŸ”Ή Active ISIN (International Securities Identification Number)

Without an active ISIN, the PAS-6 form cannot be filed.
Companies must coordinate with their Depository Participant (DP) to ensure that ISIN details are up to date.

πŸ”Ή Accurate Share Capital Records

The data submitted to the depository must match the company’s statutory registers, such as:

  • Register of Members

  • Register of Share Transfer

  • Register of Allotment

Any mismatch may result in a filing error or compliance notice.


What Happens if You Don’t File PAS-6 on Time?

Missing the 29th November 2025 deadline can result in:

  • Additional fee penalties

  • Non-compliance notices from ROC

  • Difficulty in processing future share transfers/allotments

  • Risk of corporate governance violations

  • Potential barriers during due diligence, funding, or merger processes

Therefore, timely filing is crucial for maintaining the credibility and compliance health of your company.


How Taxla Services Helps You Stay Compliant

Filing Form PAS-6 requires careful review, accuracy in share capital reconciliation, and coordination with depositories. At Taxla Services P. Ltd, we simplify the entire process for you:

✔ Verification of ISIN and DP status

✔ Checking dematerialization status of all shareholders

✔ Reconciliation of paid-up and issued share capital

✔ Error-free filing of PAS-6 within the deadline

✔ Ensuring compliance with all MCA and ROC requirements

Our experts ensure that your filings are completed accurately and on time, safeguarding your company from penalties and compliance issues.


Conclusion

Form PAS-6 is an important compliance requirement for companies transitioning toward total dematerialization and transparent share capital management. With the due date of 29th November 2025 approaching, unlisted public companies and qualifying private or Section 8 companies must act now to ensure timely and accurate filing.

Staying compliant not only protects your company from penalties but also enhances corporate credibility, investor confidence, and operational transparency.

For end-to-end support, expert guidance, and hassle-free MCA filing services—

πŸ“ž Contact us today: +91 7305701454
πŸ“§ Email: auditsiva2@gmail.com
🌐 Website: www.taxlaservices.com

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