Avil Rakshith Salins — ACS A48442, Practising Company SecretarySalins & Co.
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02 November 2026 · Updated 02 November 2026

By Avil Rakshith Salins, Practising Company Secretary

Form PAS-6: reconciliation of share capital audit report

In short

Form PAS-6 is the half-yearly reconciliation of share capital audit report. It confirms that the company's total issued capital matches the shares held in demat form with NSDL and CDSL plus any shares still in physical form. It is filed with the Registrar within 60 days of the end of each half-year and must be certified by a company secretary or chartered accountant in practice (rule 9A(8), Companies (Prospectus and Allotment of Securities) Rules, 2014).

Status as on 2 November 2026: PAS-6 for the half-year ended 30 September 2026 is due by 29 November 2026.

Who files PAS-6

CompanyFiles PAS-6?Basis
Unlisted public companyYes, every half-yearRule 9A(8)
Private company that is not a small companyYes, once it is covered by the demat requirementRule 9B applies the rule 9A demat provisions, including PAS-6, to these companies
Small company (paid-up capital up to ₹10 crore and turnover up to ₹100 crore, from 1 December 2025)NoRule 9B excludes small companies; limits under G.S.R. 880(E) dated 1 December 2025
Government companyNoExcluded from rules 9A and 9B
Nidhi company, or a wholly owned subsidiary of an unlisted public companyNoExcluded from rule 9A

A holding or subsidiary company, or a section 8 company, cannot be a small company however small its capital (section 2(85)), so it falls under rule 9B and files PAS-6.

For most private companies that were not small companies on 31 March 2023, the demat requirement applied from 30 June 2025 after MCA's extension. From then on, PAS-6 is a regular half-yearly filing, like AOC-4 and MGT-7 are yearly ones.

Due dates, fees and penalty

PAS-6 is due within 60 days of the end of each half-year of the financial year.

Half-yearPeriodPAS-6 due by
First half of FY 2026-271 April to 30 September 202629 November 2026
Second half of FY 2026-271 October 2026 to 31 March 202730 May 2027

Fees. The filing fee and any additional fee for late filing are charged under the Companies (Registration Offices and Fees) Rules, 2014, based on the company's nominal share capital. The MCA portal works out the exact amount when the form is submitted.

Penalty. The rules do not set a separate penalty for not filing PAS-6, so the general penalty in section 450 of the Companies Act applies: ₹10,000, plus ₹1,000 for each day the default continues, up to ₹2 lakh for the company and ₹50,000 for each officer in default. A missed PAS-6 is a continuing default, so the penalty keeps growing until the form is filed.

One missed PAS-6 often hides a larger problem: shares still in physical form, or allotments not credited to demat accounts. Fix the demat position first, then file.

What the report contains

  • Issued capital, and the shares held with NSDL, with CDSL and in physical form, with percentages
  • Any change in share capital during the half-year (allotment, rights, bonus, ESOP, buy-back, reduction, forfeiture) and whether NSDL and CDSL were informed
  • Shares held by promoters, directors and key managerial personnel
  • Whether the register of members is up to date
  • Demat requests confirmed within 21 days, and any pending beyond 21 days with reasons
  • The registrar and transfer agent (common agency) for share registry work
  • The details of the practising professional who certifies the report

Who certifies it: a company secretary in practice or a chartered accountant in practice, after checking the register of members, the depository records (from the registrar and transfer agent) and the share capital records.

How PAS-6 is filed

  1. Get the half-year shareholding data from the registrar and transfer agent (NSDL and CDSL holdings).
  2. Match it with the register of members and the share capital on the MCA master data.
  3. The practising professional prepares and certifies the reconciliation.
  4. File PAS-6 on the MCA V3 portal, signed by a director or the company secretary with their DSC, within 60 days of the half-year end.

We prepare and certify PAS-6 and file it on MCA, working from the half-yearly records of your registrar and transfer agent.

Frequently asked questions

Within 60 days of the end of each half-year: 29 November for April to September, and 30 May for October to March.

Yes, if it is not a small company and is covered by the demat requirement under rule 9B. Small companies and government companies do not file it.

No. A holding or subsidiary company cannot be a small company under section 2(85), so it must dematerialise its shares and file PAS-6.

A company secretary in practice or a chartered accountant in practice.

Yes. The reconciliation is due every half-year, even if the shareholding did not change.

The report shows them separately. The company must still facilitate dematerialisation, and new issues and transfers must be in demat form.

The general penalty under section 450 applies: ₹10,000 plus ₹1,000 a day while the default continues, up to ₹2 lakh for the company and ₹50,000 for each officer in default.

No. PAS-3 reports an allotment of shares within 15 days of a private placement allotment (30 days for others). PAS-6 is a half-yearly reconciliation of all shares in demat and physical form.

Sources

General information on the law as on 02 November 2026, not advice on any particular matter. Check the current MCA form and instruction kit before filing.

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