PAS-6 is a half-yearly compliance form introduced by the Ministry of Corporate Affairs (MCA) for companies holding securities in dematerialised (demat) form. It is officially known as the Reconciliation of Share Capital Audit Report and is required to ensure that the company’s share capital records match with the depository records.

This compliance was introduced to improve transparency, reduce discrepancies in shareholding data, and ensure that companies maintain accurate records of shares issued, transferred, or held in dematerialised form.

Applicability of PAS-6

PAS-6 filing is applicable to:

• Unlisted public companies in India

• Companies holding shares in demat form with NSDL or CDSL

• Companies having share capital irrespective of size

It is not applicable to listed companies, as they already follow stricter depository and stock exchange reporting requirements.

Purpose of PAS-6 Filing

The main objective of PAS-6 is to reconcile:

• Total issued share capital of the company

• Shares held in physical form (if any permitted)

• Shares held in dematerialised form

• Differences between company records and depository records

This ensures that there is no mismatch between the company’s internal records and the records maintained by depositories.

Due Date for Filing PAS-6

PAS-6 is required to be filed:

• Half-yearly basis

• Within 60 days from the end of each half-year

This means companies must file it twice a year, based on shareholding data as on:

• 31st March

• 30th September

Details Included in PAS-6 Report

The PAS-6 form includes important share capital information such as:

• ISIN details of securities

• Number of shares held in demat and physical form

• Changes in share capital during the period

• Details of dematerialisation requests

• Confirmation of reconciliation between company and depository records

• Breakup of shareholding pattern

Consequences of Non-Compliance

Failure to file PAS-6 within the prescribed timeline may result in:

• MCA penalties and additional fees

• Compliance violations under Companies Act, 2013

• Difficulties in share transfer or fundraising

• Audit observations and regulatory scrutiny

Timely filing is therefore essential for maintaining proper corporate governance.

Importance of PAS-6 Compliance

PAS-6 plays a key role in corporate compliance by:

• Ensuring transparency in shareholding structure

• Preventing fraud or discrepancies in share records

• Strengthening investor confidence

• Maintaining accurate demat records with NSDL/CDSL

• Supporting smooth corporate audits and due diligence

Documents Required for PAS-6 Filing

To prepare and file PAS-6, the following are generally required:

• Shareholding pattern of the company

• ISIN details from depositories

• Demat account statements

• Register of members

• Details of allotments and transfers

• Reconciliation statement certified by professional

Conclusion

PAS-6 is an important compliance requirement for unlisted public companies holding demat securities. Regular and accurate filing ensures legal compliance and strengthens the company’s financial credibility in the eyes of regulators and investors.