E-Form PAS-6 to be filed with ROC by Unlisted Public Companies

The Reconciliation of Share Capital Audit Report was applicable only for Listed Companies, initially which shall be filed with Stock Exchanges on a quarterly basis as per SEBI (Depositories and Participants) Regulations.

Now, the Central Government (Ministry of Corporate Affairs) has introduced a similar concept under the Companies Act, 2013 for unlisted public companies. Form PAS-6 was introduced vide Companies (Prospectus and Allotment of Securities)Third Amendment Rules, 2019 published on 22nd May 2019 which was effective from 30th September 2019. However, e-form PAS-6 was deployed on the MCA portal only on 15th July 2020.
Form PAS-6 is a half-yearly audit report prepared for reconciliation of share capital which shall be certified by a Practicing Company Secretary or a Practicing Chartered Accountant.

Section 29 (1A) of the Companies Act 2013 read with Rule 9A (8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014, states that Due Date for filing E-form PAS-6 shall be within 60 days from the end of each half of the financial year i.e. On or before 12th September 2020 for the half financial year ending on 30th September 2019 and for 31st March 2020 for the other end. Thereafter within 60 days from the end of each half-year.

For each ISIN separately it shall be filed with ROC.