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.
| 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 |
The applicability memo, the dated gap list, filed PAS-6 where due, and the compliance calendar entry that keeps the half-years from slipping.
Latest financials (for small-company tests), cap table and register of members, incorporation documents, and any existing ISIN/RTA papers.
Financial data drives the tests — provide it complete; shareholder cooperation (especially promoters dematerialising) is the company’s to obtain, with our follow-up formats.
The ISIN/RTA/depository setup execution itself lives in the companion service below; listed-company regimes are out of scope.
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.
Applicability decided on numbers, in writing.
Actions and dates laid out.
PAS-6 cycles brought current.
Setup work handed to the infrastructure scope.
Have questions about this service? Contact us for a free consultation.
Book Consultation WhatsApp UsLet our expert team help you with professional CA services tailored to your needs.
Schedule a Meeting