Act Now: PAS-6 Filing Deadline Nears for March 2025 Half-Year

As part of ongoing corporate compliance responsibilities, unlisted public companies in India are reminded of their obligation to file Form PAS-6 for the half-year ending March 31, 2025. This mandatory filing, governed under Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014, plays a key role in ensuring transparency between company records and depository systems.

Companies must complete this filing by May 30, 2025, certified by a practicing Chartered Accountant (CA) or Company Secretary (CS).

What is Form PAS-6?

Form PAS-6 is a half-yearly reconciliation statement of share capital, designed specifically for unlisted public companies that have issued shares in dematerialized form. It enables cross-verification between the company’s internal records and data available with depositories like NSDL (National Securities Depository Limited) and CDSL (Central Depository Services Limited).

This filing ensures that the company’s issued, allotted, and dematerialized share capital is consistent and accurately reported.

Applicability of PAS-6 Filing

Who should file PAS-6?

• Applicable To:
  • All unlisted public companies which have issued securities in dematerialized form.
  • Companies required to dematerialize securities as per Rule 9A.
• Not Applicable To:
  • Private limited companies
  • Listed companies
  • Companies that have not issued shares in demat form

The intention behind limiting the applicability is to tighten oversight on public fundraising entities, without overburdening private firms not involved in public capital markets.

Filing Timeline & Due Date

The form must be filed within 60 days from the end of each half-year period. For the period ending March 31, 2025, the last date to submit PAS-6 is:

📅 May 30, 2025

Timely submission is essential to maintain good standing with the Ministry of Corporate Affairs (MCA) and to avoid penalties or red flags during compliance audits.

Key Details Required in Form PAS-6

Filing Form PAS-6 involves providing a number of critical data points. These include:

• ISIN (International Securities Identification Number) of each class of security
• Total number of shares issued, held in physical form, and dematerialized form
• Names of depositories (NSDL/CDSL) and quantity held with each
• Details of any changes in share capital during the half-year
• Names and shareholding details of promoters, directors, and key personnel
• Reason for any mismatch between the issued and demat capital
• Digital certification by a practicing CA/CS

The company must ensure that all the information is accurate and aligns with its statutory records and filings.

Why is PAS-6 Filing Important?

Filing PAS-6 serves multiple regulatory and operational benefits:

✅ Ensures accurate reconciliation between company records and depositories

✅ Facilitates transparency in capital structure and shareholder holdings

✅ Helps the government track benami transactions and unauthorized capital movements

✅ Prevents regulatory scrutiny and penalty proceedings

✅ Builds trust among investors, auditors, and stakeholders

In an era of increased digital governance and stricter compliance norms, skipping such filings can significantly harm a company’s credibility.

Frequently Asked Questions (FAQs)

Q1. Is PAS-6 applicable to private limited companies?
No, only unlisted public companies that have issued shares in dematerialized form are required to file PAS-6.

Q2. Who can certify Form PAS-6?
The form must be certified by a Practicing Chartered Accountant (CA) or Practicing Company Secretary (CS).

Q3. What is the due date for PAS-6 for the half-year ending March 2025?
The due date is May 30, 2025.

Q4. Can PAS-6 be filed without a digital signature?
No, Digital Signature Certificate (DSC) is mandatory for certification and filing on the MCA portal.

Q5. What if a company fails to file PAS-6 on time?
Failure to file can lead to penalties, increased compliance scrutiny, and may affect the company’s future MCA filings.

Conclusion

Compliance with Form PAS-6 is a critical checkpoint in a company’s corporate governance roadmap. As the May 30 deadline approaches, companies must gather the necessary data, verify their dematerialization records, and coordinate with professionals for timely filing.

In today’s regulatory environment, proactive compliance is not just a requirement but a competitive advantage. Stay ahead, file on time, and maintain your company’s credibility in the eyes of regulators and stakeholders.

📅 Published on: 05 May 2025
✍️ Author: CS Chhavi Goyal