Published May 16, 2026 4 Min Read

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Introduction

Form PAS 6 is an important compliance filing introduced by the Ministry of Corporate Affairs (MCA) for certain unlisted public companies in India. The form helps maintain transparency and accuracy in records related to securities held in dematerialised form. Businesses that issue securities must ensure proper reconciliation between their records and those maintained by depositories and registrars.

Understanding the PAS 6 form is essential for company directors, compliance professionals, company secretaries, and business owners managing regulatory obligations. This guide explains the meaning of Form PAS 6, its applicability, filing process, due dates, penalties, and other important compliance requirements in a simple and easy-to-understand manner.

What is the Form PAS 6?

Form PAS 6 is a half-yearly reconciliation audit report that unlisted public companies must file with the Registrar of Companies (ROC). The form is filed under Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014.

The primary purpose of PAS 6 is to reconcile the total issued capital of a company with the capital held in dematerialised form through depositories. It helps verify whether the company’s records match the details maintained by depositories and registrars.

The form includes information related to International Securities Identification Number (ISIN), changes in share capital, dematerialised shares, and physical shares. A practising company secretary or chartered accountant generally certifies the form before submission.

The PAS 6 filing process improves transparency, reduces discrepancies in securities records, and supports better corporate governance for unlisted public companies.

Applicability of the Form PAS-6

The PAS 6 applicability mainly covers certain unlisted public companies that issue securities in dematerialised form. The following entities are generally required to file the form:

  • Unlisted public companies governed under Rule 9A of the Companies Act, 2013
  • Companies that have issued equity shares, preference shares, debentures, or other securities in demat form
  • Companies with an active ISIN for their securities
  • Companies required to reconcile issued capital with depository records every half year
  • Companies that maintain records with depositories such as NSDL or CDSL

The following entities are generally exempt from PAS 6 filing:

  • Private limited companies
  • Listed companies already governed under SEBI regulations
  • Government companies in certain notified cases

Key content of Form PAS 6

Details included in Form PAS 6

Form PAS 6 contains important information related to the reconciliation of securities issued by an unlisted public company. The form ensures that the company’s share capital records remain accurate and updated.

Key details included in the PAS 6 form are:

  • Corporate Identification Number (CIN) of the company
  • Name, registered office address, email address, and contact details of the company
  • Details of the capital structure and issued securities
  • ISIN details allotted to the company’s securities
  • Number of shares held in dematerialised form with NSDL
  • Number of shares held in dematerialised form with CDSL
  • Number of shares held in physical form
  • Total issued and listed capital of the company
  • Details of changes in share capital during the reporting period
  • Information about shares converted from physical form to demat form and vice versa
  • Details of discrepancies, if any, between company records and depository records
  • Information related to the company secretary, registrar, and share transfer agent
  • Certification from a practising professional confirming the correctness of the information

These details help regulators monitor compliance and ensure accurate maintenance of securities data. The form also reduces the possibility of mismatches in company records and strengthens transparency in corporate reporting.

Due date for filing Form PAS 6

The PAS 6 due date is linked to each half-year reporting period. Companies must file the form within 60 days from the conclusion of the relevant half year.

Timely filing is important to avoid penalties and compliance-related issues. Businesses should regularly review their securities records and coordinate with depositories before submission.

Reporting periodPAS 6 last date
Half year ending 31 MarchOn or before 29 May
Half year ending 30 SeptemberOn or before 29 November

Process of filing the Form PAS 6

The filing process for PAS 6 involves several compliance and verification steps. Companies should ensure that all information is accurate before submission.

  • Confirm whether the company falls under PAS 6 applicability requirements
  • Obtain and verify the ISIN details for all eligible securities issued by the company
  • Reconcile the issued share capital with records maintained by NSDL, CDSL, and the registrar and share transfer agent
  • Collect details of physical shares and dematerialised shares for the reporting period
  • Identify any changes in capital structure, including transfers, allotments, or conversions
  • Prepare the reconciliation details carefully to avoid discrepancies
  • Download the latest version of the PAS 6 form from the MCA portal
  • Fill in company details such as CIN, registered office address, and authorised signatory information
  • Enter complete details related to securities, ISIN, and shareholding reconciliation
  • Attach supporting documents and certifications, if required
  • Get the form certified by a practising company secretary or chartered accountant
  • Use a valid Digital Signature Certificate (DSC) for authorised signatories
  • Upload the completed e-form on the MCA portal
  • Pay the applicable filing fees online through the MCA system
  • Preserve acknowledgement receipts and filed records for future compliance reference

Since the entire filing process is digital, companies should ensure proper maintenance of electronic records and compliance documents.

Penalty for non-filing of Form PAS 6

Failure to comply with PAS 6 filing requirements may lead to penalties and regulatory consequences for the company and its officers.

Possible penalties for non-filing or delayed filing include:

  • Additional filing fees charged by the MCA for delayed submission
  • Penalties imposed under the Companies Act, 2013 for non-compliance
  • Regulatory scrutiny due to discrepancies in share capital records
  • Compliance issues during corporate restructuring, fundraising, or audits
  • Difficulties in maintaining accurate dematerialised securities records
  • Increased risk of notices from regulatory authorities
  • Delays in corporate actions involving securities and share transfers
  • Potential restrictions relating to securities handling and dematerialisation processes
  • Liability for officers responsible for maintaining statutory compliance

Companies should maintain updated records and complete filings within the prescribed PAS 6 due date to avoid legal and administrative complications.

Disclaimer: Regulatory provisions, penalties, and filing requirements may change from time to time based on MCA notifications and amendments under applicable laws. Businesses should consult qualified professionals for updated compliance guidance.

Conclusion

Form PAS 6 plays an important role in maintaining transparency and accuracy in the records of unlisted public companies. The form helps reconcile issued securities with depository records and supports proper compliance under the Companies Act, 2013.

Understanding the PAS 6 filing process, due dates, applicability, and penalties can help companies avoid delays and regulatory issues. Businesses should ensure proper maintenance of dematerialised securities records, timely reconciliation, and accurate filing through the MCA portal. Regular compliance not only reduces legal risks but also strengthens corporate governance and operational transparency for companies handling securities in demat form.

Frequently asked questions

Can I file PAS 6 without ISIN?

No, an ISIN is generally required for filing the PAS 6 form. Since the form focuses on reconciliation of dematerialised securities, companies must provide valid ISIN details to match depository records with company share capital records.

What is the penalty for delay in filing of Form PAS-6?

Delayed filing of PAS 6 may result in additional filing fees, penalties under the Companies Act, 2013, and possible regulatory scrutiny. Continued non-compliance may also create operational and legal complications for the company and responsible officers.

How to submit E-Form PAS-6?

To submit E-Form PAS-6, companies must complete the form on the MCA portal, attach required details, obtain professional certification, apply digital signatures, and upload the form online along with payment of applicable filing fees.

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