# PAS-6 Share Capital Reconciliation

> Unlisted public companies and private companies that are not small companies must hold their securities in demat form and file Form PAS-6 every half-year — by 29 November for the half to 30 September and by 30 May for the half to 31 March — reconciling issued capital with depository records. From 1 December 2025 a small company is one with paid-up capital up to ₹10 crore and turnover up to ₹100 crore.

Practice: Company Secretary & Corporate Compliance — https://www.industax.com/services/company-secretary/

Rule 9B requires non-small private companies to issue securities only in demat form and to dematerialise existing holdings; the deadline was extended to 30 June 2025. That means appointing a registrar and share transfer agent (RTA), getting an ISIN from NSDL and CDSL, and asking shareholders to open demat accounts.

PAS-6 is prepared from the RTA's records and a practising professional's reconciliation. Because the small-company limits changed on 1 December 2025, some companies moved out of the requirement and others moved in — we check your status each year.

## Key facts

| Item | Detail |
| --- | --- |
| Who | Unlisted public companies (Rule 9A) and non-small private companies (Rule 9B) |
| Due dates | 29 November and 30 May |
| Small company (from 1 Dec 2025) | Paid-up capital ≤ ₹10 crore and turnover ≤ ₹100 crore |
| Demat set-up | RTA appointment, ISIN from NSDL/CDSL, shareholder demat accounts |

## Who needs this

- Unlisted public companies
- Private companies above the small-company limits
- Companies preparing for institutional investment

## What's included

- Applicability check
- RTA and ISIN coordination
- Shareholder dematerialisation support
- Half-yearly PAS-6 filing

## Documents

- Audited financials (for small-company test)
- Register of members
- RTA agreement and depository records

## Process

1. **Test** — Small-company status checked against the new limits.
2. **Demat** — RTA appointed and ISIN obtained if not done.
3. **Reconcile** — Share capital reconciled with depositories.
4. **File** — PAS-6 filed by the half-yearly due date.

## FAQs

### Does every private company have to dematerialise shares?

No. Small companies are exempt. Private companies above the limits (paid-up capital over ₹10 crore or turnover over ₹100 crore from 1 December 2025) must.

### What are the PAS-6 due dates?

29 November for the half-year ending 30 September and 30 May for the half-year ending 31 March.

### What is needed to dematerialise shares?

An agreement with an RTA, an ISIN from NSDL and CDSL, and demat accounts for shareholders.

## Official sources

- Ministry of Corporate Affairs — MCA21 portal: https://www.mca.gov.in/
- NSDL: https://nsdl.co.in/
- CDSL: https://www.cdslindia.com/

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Canonical page: https://www.industax.com/services/company-secretary/pas-6-filing
Publisher: Indus Tax — CA-led tax and compliance firm (https://www.industax.com). Contact: info@industax.com, 9059139258.
This is general information, not advice for your specific facts.