Services for clients across India. Applicable state, sector and professional requirements are assessed before an engagement.
The demat mandate reached private companies: most non-small private companies must now issue securities in dematerialised form and file PAS-6 half-yearly — a rule many discovered only when a transaction stalled. The first question is applicability on your facts; the second is the honest to-do list.
When this service is typically required
- Confirming whether the Rule 9B mandate covers your company (and from when)
- A share issue or transfer is planned — new issues must be in demat where covered
- PAS-6 half-yearly reporting is due or has never been filed
- Diligence or a bank flagged demat status
Indicative scope
- Applicability memo: small-company tests, timelines, promoter-holding rules on your facts
- Gap list: what must happen (ISIN, RTA, promoter demat) and by when
- PAS-6 preparation and filing with reconciliation to the register
- Coordination into the setup engagement where infrastructure is needed
Key points at a glance
| Item | Position |
|---|---|
| Coverage | Private companies other than small companies, per the amended rules |
| Consequence | Covered companies cannot issue/allot in physical form; holders face transfer constraints |
| PAS-6 | Half-yearly reconciliation filing once ISIN exists |
| Reality | Transactions are where non-compliance surfaces — at the worst time |
Deliverables
The applicability memo, the dated gap list, filed PAS-6 where due, and the compliance calendar entry that keeps the half-years from slipping.
Information and documents generally required
Latest financials (for small-company tests), cap table and register of members, incorporation documents, and any existing ISIN/RTA papers.
Engagement process
Client responsibilities, assumptions and reliance
Financial data drives the tests — provide it complete; shareholder cooperation (especially promoters dematerialising) is the company’s to obtain, with our follow-up formats.
Scope exclusions
The ISIN/RTA/depository setup execution itself lives in the companion service below; listed-company regimes are out of scope.
Frequently asked questions
We are tiny — surely exempt?
“Small company” is a defined test, not a feeling — capital and turnover limits decide it, and growth can end the exemption. The memo answers it and diarises the re-test.
What actually breaks if we ignore this?
New allotments risk invalidity questions, transfers jam, penalties accrue, and funding rounds stall on a fixable defect discovered late.
Our shares are with two founders only. Still bother?
If covered, yes — the mandate does not care how few shareholders you have; it cares about the class of company.
PAS-6 with no movements — still file?
Yes, the reconciliation is periodic regardless of movement, once the framework applies.
The applicable scope, documentation, professional responsibilities and timelines are agreed in an engagement letter before commencement.
ISIN/RTA Setup (execution)ROC ComplianceAllotments in DematRequest a Scope DiscussionThis page describes the service in general terms as on 6 August 2026 and is not professional advice or an assurance of any outcome. Registrations, filings, refunds and departmental outcomes depend on facts and the concerned authority. Figures and due dates change; verify current positions before acting.
| Compliance | Due | Note |
|---|---|---|
| DPT-3 (deposits/loans return) | 30 June (annual) | Covers director loans and advances |
| DIR-3 KYC | 30 September | Now triennial for unchanged particulars |
| AGM (other than first) | 30 September | First AGM: 9 months from first FY end |
| AOC-4 / MGT-7 | 30 / 60 days from AGM | Rs 100 per day per form if late |
| MSME Form 1 | 30 April / 31 October | If MSE dues pending beyond 45 days |
| CCFS-2026 amnesty | Till 31 August 2026 | 90% additional-fee waiver + immunity |
Dates as generally applicable on 15 July 2026; extensions/notifications can change them — confirm current dates before relying.