Introduction
The Ministry of corporate affairs has launch a new form i.e. Form PAS-6 ‘Reconciliation of Share Capital Audit Report’ which is which is applied to unlisted public companies to the Registrar of Companies (ROC). The main objective of Form PAS-6 is to record the changes and details in the share capital of companies on a half-yearly basis.
According to Rule 9A(8) of the Companies (Prospectus and Allotment of Securities) 2014, every unlisted public company have to submit Form PAS-6 duly certified by a Company Secretary or Chartered Accountant in practice to the Registrar of companies within 60 day of each half year.
Filing of Form PAS-6
Form PAS-6 is concerned with the filing of the reconciliation of the share capital audit report (half-yearly) of unlisted public companies. The objective of this form is to recognize any difference observed in the issued capital and the capital held in dematerialized form of a public company.
All unlisted public companies that issue shares in accordance with Rule 9A of the Companies (Prospectus and Allotment of Securities) Third Amendment Rules, 2019 shall submit Form PAS-6. However, there are some unlisted public companies need not file from PAS-6.
- Government company
- Wholly owned subsidiary
- Nidhi company
Inclusions of the Form PAS-6
- Company incorporation number (CIN) and International Securities Identification Number (ISIN) for each type of security.
- Details of the CA/CS of the Company, if any and practising CS/CA certifying the form.
- Details of the total shares held bypromoters, directors, and KMP in physical and dematform.
- Details about the changes in the share capital during the half-year in the form of rights issue, bonus issue, ESOPs, conversion, private placement, capital reduction, buyback, amalgamation, forfeiture and others.
- All details about total number of Demat requeststhat confirmed after 21 days and Demat requests that pending beyond 21 days with the reason for such delay.
- Details of the company’s capital such as issued capital, shares held in dematerialised form in NSDL, CDSL, physical form and the reason for any differences in the capital.
Process of filing the form PAS-16
- From the MCA website download Form PAS-6.
- Fill in all the required details of Form PAS-6.
- Attach the digital signature of the Director, CFO, CEO and secretary of company.
- Provide the DIN in case of the digital signature by a director, Membership number in case of secretary digital signature, PAN card of CFO or CEO in case of attaching their digital signature.
- Enter the membership/COP number and attach the digital signature of a practising CA or CS and submit the e-form along with the prescribed fees.
DOCUMENTS REQUIRED IN FORM PAS-6
Form PAS-6 under the Companies Act, 2013, required specific documents and information to be submitted for reconciliation of share capital audit. Please note that the requirements and documents may have been updated since then. Here are the documents and information typically required for filing Form PAS-6:
1.Details of the Company:
Company’s Corporate Identity Number (CIN).
Name of the Company.
Address of the registered office.
Email address and phone number of the company.
2.Changes in Share Capital During the Financial Year:
Changes in the authorized share capital.
Details of shares issued during the financial year.
Details of shares bought back by the company.
Details of shares redeemed by the company.
Details of shares forfeited by the company.
Details of shares held in the dematerialized and physical forms.
3.Details of Securities Held by Depositories:
Name of the depository.
ISIN (International Securities Identification Number) of the securities.
Details of securities held in dematerialized form, including the number of securities and their face value.
Details of securities held in physical form, including the number of securities and their face value.
Details of discrepancies between the company’s records and the depository’s records.
4.Compliance with Companies Act, 2013, and Related Rules:
Details of compliance with the Companies Act, 2013, and any other relevant rules and regulations.
5.Attachments:
The auditor’s certificate confirming the reconciliation of the share capital audit.
Any other relevant documents as required by the MCA.
Due date of filing form PAS-6
Every unlisted public company must file form PAS-6 with the ROCwithin 60 days from the conclusion of the half-year. The due date of filing Form PAS-6 shall be:
| Particular | Due dates |
| For period April- September | 29th November |
| For period October- March | 30th May |
