WikiMCA
Capital

PAS-6

Reconciliation of share capital audit. Half-yearly reconciliation of dematerialised share capital.

Who filesUnlisted 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 lawRule 9A of the Prospectus and Allotment Rules
DueWithin 60 days of the end of each half year.
How it is filedMCA V3.
FeeNormal fee.
CertificationA 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

  1. Obtain the ISIN.
  2. Reconcile issued, demat and physical holdings.
  3. 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.