/ ROC Deadline Alert · Updated 2026-10-22
Form PAS-6 September 2026 Half-Year, Rule 9B demat half-yearly reconciliation.
Form PAS-6 half-yearly return for September 2026 period is due 29 November 2026. Mandatory for all Rule 9B companies (unlisted public + private except small companies / government / Nidhi). Reconciles share capital: authorised + issued + paid-up + demat form + physical form + reasons for difference. CA certification required. Here's the compliance alert.
DC
Written by CA Durgesh Chavda
Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn
/ Who must file PAS-6
Rule 9B scope.
- All unlisted public + private companies (except small companies, government companies, Nidhi companies) that have securities in demat form under Rule 9B.
- Small company threshold: paid-up capital up to INR 4 crore + turnover up to INR 40 crore (Section 2(85)). Most growth-stage startups cross this threshold.
- Half-yearly filing: within 60 days of half-year end (30 September + 31 March).
- September 2026 period: due 29 November 2026.
- March 2027 period: due 30 May 2027.
/ What's in Form PAS-6
The reconciliation.
- Authorised share capital + issued + subscribed + called-up + paid-up at half-year end.
- Breakup by class of security (Equity + Preference + Convertible instruments).
- Reconciliation: shares in demat form (NSDL + CDSL) vs physical form + issued but not demat'd + bought back + cancelled.
- Changes during half-year: allotments + buyback + transmission + any share capital change.
- Reasons for any difference between issued capital and demat + physical total.
- CA certification confirming reconciliation accuracy.
/ Common filing issues
Where PAS-6 trips.
- Shareholders unresponsive to demat request - still in physical form 2 years after Rule 9B became mandatory.
- Reconciliation gaps between company's share register + NSDL / CDSL records.
- ESOP exercise during half-year not reflected in demat form yet (processing timing).
- Buyback / bonus / rights issue reconciliation.
- Lost physical certificates - duplicate issuance under Rule 6 pending.
- CA certification requires reconciliation workpapers - must prepare in advance.
/ Compliance checklist
The November 2026 action list.
- Export shareholder register as of 30 September 2026.
- Request NSDL + CDSL depository data for same date.
- Reconcile: company register vs NSDL + CDSL data + physical holders.
- Identify unresponsive demat shareholders (physical form 2+ years post Rule 9B).
- Document any reconciliation differences with narrative.
- Compile half-year changes: allotments / buyback / transmission / ESOP exercise.
- CA review + certification.
- File Form PAS-6 via MCA v3 portal by 29 November 2026.
- Attach: CA certificate + reconciliation workpapers + specific annexures as applicable.
Last updated: 2026-10-22.
/ Ready when you are
Form PAS-6 September 2026 period due 29 November. 38 days.
Share capital reconciliation + demat / physical breakup + CA certification + MCA v3 filing. BQP: half-yearly recurring + Rule 9B remediation integrated.
FAQ
Common questions, answered.
When is PAS-6 due for September 2026 half-year?
29 November 2026 - within 60 days of 30 September 2026 half-year end. For March 2027 period: 30 May 2027. Filed via MCA v3 portal with CA certification + reconciliation workpapers.
Which companies must file PAS-6?
All unlisted public and private companies (except small companies, government companies, Nidhi companies) that have securities in demat form under Rule 9B. Small company threshold: paid-up capital up to INR 4 crore + turnover up to INR 40 crore under Section 2(85). Most growth-stage startups cross threshold.
What CA certification does PAS-6 require?
Chartered Accountant certification confirming: share capital reconciliation accuracy, authorised + issued + paid-up matching, demat + physical reconciliation, any differences explained with reasons. Signed by practicing CA with ICAI membership + UDIN (Unique Document Identification Number).
What if I still have physical-share holders at September 2026?
File PAS-6 reflecting the physical holders in reconciliation. Narrative explanation that company has attempted demat (RPAD letters, emails, follow-ups) but specific shareholders remain unresponsive. Documentation of attempts is key - demonstrates company's reasonable efforts to comply with Rule 9B obligation to facilitate (not force) demat.
What's the late fee for missed PAS-6?
Section 47 CGST Act late fee - not applicable here. Companies Act Section 450 default penalty: up to INR 10,000 for first default + INR 1,000 per day of continuing default. More materially: Section 450 for every officer in default + ROC may initiate adjudication proceedings.
Does BQP handle PAS-6 + Rule 9B demat remediation integrated?
Yes - end-to-end. Rule 9B demat gap assessment + ISIN application + shareholder communication + demat execution + PAS-6 half-year filing + CA certification + ongoing Rule 9B compliance. For companies with 20-500+ shareholders. Standard annual engagement + priority during November + May PAS-6 windows. WhatsApp +91 78018 87130.
Related reading