PAS-6
Reconciliation of share capital audit. Half-yearly reconciliation of dematerialised share capital.
| Who files | Unlisted public companies under Rule 9A. Private companies brought in by Rule 9B follow the demat obligation; confirm whether PAS-6 is asked of that class on the current form instruction. |
|---|---|
| Governing law | Rule 9A of the Prospectus and Allotment Rules |
| Due | Within 60 days of the end of each half year. |
| How it is filed | MCA V3. |
| Fee | Normal fee. |
| Certification | A company secretary in practice. |
The law
Rule 9A, for an unlisted public company. Rule 9B is the private-company demat rule and is aimed at private companies other than small companies. Whether that class must file PAS-6 is read from the current instruction kit. A public company is never a small company.
The deadline
Within 60 days of the end of each half year.
If it is missed
A late form draws the additional fee. Being a small company does not take an unlisted public company out of Rule 9A.
The remedy
Obtain the ISIN, reconcile issued capital with demat and physical holdings, and file. A reconciliation that does not match the register of members is not a filing to defend.
When to file
- The company is an unlisted public company and must hold securities in demat.
Attachments
- Depository statements
- Register of members
Steps
- Obtain the ISIN.
- Reconcile issued, demat and physical holdings.
- File within 60 days of 31 March and of 30 September.
Questions
- Does a small private company file PAS-6?
- Rule 9B dematerialisation is aimed at private companies other than small companies. A company that is small under the December 2025 limits is outside that private-company demat mandate. Unlisted public companies remain inside Rule 9A.
Not yet verified against the latest textRule-sourced — Rule 9A. Rule 9B scope is summarised and should be read with the amending notification.