Everything about Rule 9A and e-Form PAS-6

Everything About Rule Form Pas 6

All the unlisted Public companies except Nidhi Company, Government Company, or wholly-owned subsidiary company need to issue the securities in only dematerialized form. It was made mandatory with notification released on September 10, 2018, Rule 9A of Companies (Prospectus and Allotment of Securities) Rules, 2014, was inserted.

In this article, we are providing details of Rule 9A of Companies (Prospectus and Allotment of Securities) Rules, 2014 and all the other details required while Filing e-Form PAS-6 (Reconciliation of Share Capital Audit Report on a half-yearly basis.)

Responsibilities of the unlisted public companies under rule 9A

Every Unlisted Public Company shall

  • Issue securities in Demat form only.
  • Promote dematerialization of all its existing securities.
  • Before making any offer for the issue, bonus issue, right issue, buyback, it is necessary to ensure that the entire holding of its promoter, director, KMP is in Demat form.
  • Provide ISIN (International Security Identification Number) facility for each type of security and keep all your existing security holders up-to-date about such a facility.
  • Ensures that it shares timely payments to the depository, the registrar for an issue, and the share transfer agent according to their mutual agreement.
  • Ensures that it manages the security deposit every time with the depository and registrar on an issue and share the transfer agent in such a practice that is or may be agreed between the participants.
  • It complies with the rules or directions or guidelines or even circulars released by SEBI or Depository from time to time.
  • Furnish MCA Form PAS-6 to the Registrar within a time period of sixty days from the end of each half-year properly certified by CS or CA in practice.


The process used to convert the physical certificate of an investor into an equivalent number of securities in electronic form is known as Dematerialization

Every holder of securities of Unlisted Public Company

  • Who means to transfer such securities on or after October 2, 2018, their securities will be demonetized prior to transfer;
  • Who subscribes to any securities of an unlisted public company on or after October 2, 2018, will ensure that all their existing securities are kept in the demonetized form prior to such subscription.

The E-form PAS-6 can be downloaded from the official MCA website for filing from 15th July 2020. The last date for filing e-form PAS-6 is 60 days from 30 May 2022.

You need to keep in mind that A private company that is a subsidiary of a public company falls under Rule 9A.

Let’s take a look at the details required while filing Form PAS-6.

PAS-6 Requires the following Details

  • CIN
  • Basic Details: Name, email id, Phone number, and address of the company.
  • ISIN: ISIN stands for International Securities Identification Number, and it is a unique 12-digit alphanumeric identification number (e.g. INE383C01018) assigned for security and shares. Equity issued by the same issuer but fully paid up, partly paid up, with differential voting /dividend rights will have different International Securities Identification Numbers. E-form PAS-6 will be filed for each and every ISINs of securities.
  • Period of filing
  • Details of Capital of Company:
  • Details of changes in share capital during the half-year under consideration: Any change in share capital in the form of Rights, Bonus, ESOPs, Private placement, Amalgamation, Buyback, Conversion, Capital Reduction, Forfeiture, and others during the half-year under consideration will be denoted here.
  • Details of Shares held by Provide details of shares held by promoters, directors, and KMPs as Demat or physical form.
  • Details of Company Secretary of the Company: Requires PAN, name, membership number, and address, email, phone number in this section.
  • Details of CA/CS certifying the form: It asks for Name, Address, E-mail, Telephone number.
  • Some additional but basic details.
  • Attachments (optional, if any)
  • Make sure that the online form (e-form) is digitally signed by a CA or CS in practice.

It is to be noted that, Under this rule, complaints of security holders of non-registered public companies will be filed before the IEPF Authority

That’s all about Rule 9A and Form PAS-6, this article is prepared and published for information purposes on the basis of details available at the time of the preparation. However, if you want to know more or have more details feel free to contact us.

SAG RTA is the best agency for complete RTA-based Services such as dematerialization, miscellaneous RTA process like name, address change. Also, the SAG RTA handles the complete operational duties of its mutual fund clients to cater to their back-office related compliance.

SAG RTA is the first Registrar and Transfer Agent in Rajasthan and has headquarters behind the world trade park with complete modern infrastructure having the latest desktops machines and intercom along with 50+ expert executives.

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