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PAS-6 – Reconciliation of Share Capital Audit Report (Half-Yearly)

Who Files This?

Every unlisted public company must file Form PAS-6 to reconcile its share capital records with the depository records (NSDL/CDSL).

Applicability Criteria

  • Mandatory for all Unlisted Public Companies, including Nidhi, Section 8, and Government Companies.

  • Not applicable to:

    • Private Limited Companies.

    • Listed Companies (covered separately by SEBI).

Why It Matters

PAS-6 ensures that a company’s issued, subscribed, and paid-up capital matches with the depository data, avoiding fraud or discrepancies in ownership records.

Process of Filing

  1. Company appoints a Practicing Company Secretary (PCS) to conduct reconciliation audit.

  2. PCS verifies issued vs. dematerialized/physical shares.

  3. Report is certified and filed in Form PAS-6 through MCA portal.

Due Date

  • Within 60 days from the end of each half-year (i.e., by 30th May and 29th November every year).

Penalty for Non-Compliance

  • Company: Penalty of ₹1,000 per day of default (up to ₹5 lakh).

  • Officers in Default: Penalty up to ₹25,000.

How LTC Helps

  • Acting as certifying PCS for PAS-6.

  • Reconciling share capital records with depositories.

  • Ensuring error-free and timely filing.

  • Advisory for unlisted companies on dematerialization and compliance