MCA Alert: File PAS-6 for Half-Year Ending March 2025 on Time

The Ministry of Corporate Affairs (MCA) has issued a crucial reminder for unlisted public companies to file Form PAS-6 for the half-year ending March 31, 2025. This filing is essential to ensure compliance with the Companies Act, 2013, particularly for companies that have issued shares in dematerialized form. With the deadline approaching fast, it’s important to understand what this form entails, who it applies to, and the consequences of missing the due date.

What is Form PAS-6?

Form PAS-6 is a Reconciliation of Share Capital Audit Report that must be filed by unlisted public companies. This form reconciles the total number of shares held in the depositories (NSDL and CDSL) with the issued share capital of the company.

Introduced as part of the Companies (Prospectus and Allotment of Securities) Third Amendment Rules, 2019, PAS-6 ensures transparency in the shareholding structure of unlisted companies. The objective is to curb fraudulent practices and keep shareholding records consistent across platforms.

Who Must File PAS-6?

The following entities are required to file PAS-6:

• All unlisted public companies that have issued shares in dematerialized form
• Companies that are not listed on any stock exchange but have shareholders holding shares in electronic mode

Note: Private limited companies are currently exempt from this compliance.

What is the Deadline?

For the half-year ending on March 31, 2025, the due date to file Form PAS-6 is:

📅 May 30, 2025 (i.e., within 60 days from the end of the half-year)

Filing should be completed well before the deadline to avoid technical issues or last-minute errors.

Certification Requirement

Form PAS-6 must be digitally signed and certified by either of the following professionals:

• A Practicing Chartered Accountant (CA)
• A Practicing Company Secretary (CS)

Their verification assures the accuracy of the data submitted and aligns it with statutory norms.

Key Information Required in PAS-6

When preparing to file PAS-6, companies should be ready with the following data:

• ISIN (International Securities Identification Number)
• Details of total issued and dematerialized shares
• Information on changes in share capital during the half-year
• Number of shares held in physical and demat form
• Details of the company’s registrar and transfer agent (RTA)
• Reason for any differences in capital

Penalty for Non-Compliance

Non-filing or delayed filing of Form PAS-6 can attract penalties under the Companies Act, including:

• Monetary fines on the company and defaulting officers
• Disqualification of directors for repeated non-compliance
• Increased scrutiny in future filings
• Negative impact on credibility with investors or during audits

FAQs About PAS-6 Filing

❓1. Is PAS-6 applicable to private limited companies?

No, currently only unlisted public companies are required to file PAS-6. Private limited companies are exempt as of now.

❓2. Can a Director sign PAS-6?

No. PAS-6 must be certified digitally by a Practicing CA or CS. A director cannot self-certify the form.

❓3. Is filing required if there were no changes in share capital?

Yes. PAS-6 needs to be filed even if there were no changes in the shareholding during the half-year period.

❓4. What if a company fails to file PAS-6?

Failure to file can result in monetary penalties and legal consequences as per Section 450 of the Companies Act. It may also affect future regulatory approvals and filings.

❓5. Can PAS-6 be revised after submission?

As of now, no provision exists for revising PAS-6 once it has been filed. Accuracy before filing is crucial.

Conclusion

Form PAS-6 is more than just a compliance form—it represents a vital step toward ensuring transparency and proper corporate governance for unlisted public companies. With the May 30, 2025 deadline approaching for the half-year ending March 31, 2025, companies should act quickly, gather required data, and coordinate with their compliance professionals to file accurately and on time.

By staying compliant with PAS-6 requirements, companies not only avoid penalties but also strengthen their credibility and corporate governance practices.

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📞 Need assistance with Form PAS-6 filing or compliance support? Connect with our expert CAs and CSs today.

📅 Published on: 13 May 2025
✍️ Author: CS Chhavi Goyal