Form PAS-6 Explained: Purpose, Applicability And Half-Yearly Reporting

Reviewed on: 31 July 2026. Reviewed by Abhipra RTA Team.

Form PAS-6 is the half-yearly reconciliation of share capital audit report used to compare a company's issued capital with securities held in demat form with NSDL, demat form with CDSL and physical form. For companies covered by Rule 9A, the filing is made to the Registrar within 60 days from the conclusion of each half year and is certified by a practising company secretary or chartered accountant.

Company secretary, chartered accountant and RTA professional reviewing a Form PAS-6 reconciliation file

Why Form PAS-6 Exists

PAS-6 is intended to make the company's share-capital records, depository records and physical-security records speak the same language. It is not only a data-entry form. It is a control report that asks whether the issued capital agrees with demat and physical holdings, whether any difference exists, whether demat requests remain pending, and whether the company has a common agency for share registry work.

Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules requires covered unlisted public companies to facilitate dematerialisation, secure an ISIN for each type of security and submit Form PAS-6 within 60 days from the conclusion of each half year. Rule 9A also says differences between issued capital and capital held in dematerialised form should be brought to the notice of the depositories.

Applicability And Key Dates

For unlisted public companies governed by Rule 9A, PAS-6 is a half-yearly filing. The practical half-year periods are 1 April to 30 September and 1 October to 31 March. On a normal 60-day count, the 31 March half year is usually tracked to 30 May, and the 30 September half year is usually tracked to 29 November. Companies should still verify the MCA portal, form availability, holidays and any specific regulatory relaxation before final filing.

Rule 9B applies to private companies other than small companies, subject to exemptions and timelines. Because Rule 9B imports parts of the Rule 9A framework mutatis mutandis, PAS-6 treatment for a private company should be reviewed against the latest MCA form, portal behaviour and professional advice before filing. REQUIRES HUMAN LEGAL REVIEW.

The 30 June 2025 extended compliance date for certain non-producer private companies that were non-small as at 31 March 2023 is already a past date as of 31 July 2026.

Indicative PAS-6 half-year reporting calendar
Half-year end Normal 60-day filing target Preparation focus
31 March 30 May Close annual capital movements, reconcile demat/physical holdings and obtain certification.
30 September 29 November Track half-year allotments, transfers, demat requests, pending items and depository differences.

Data That Should Reconcile

The core PAS-6 control is straightforward: issued capital should reconcile with securities held in NSDL, securities held in CDSL and securities still in physical form, ISIN-wise. If there is a difference, the company should investigate the reason rather than force the numbers to match.

ISIN-wise reconciliation logic before Form PAS-6 certification
Data point Where it normally comes from Control question
Issued capital for the ISIN Register, board/allotment records, filings and financial statements Does the issued quantity match the approved and filed security class?
NSDL demat holding Depository/RTA holding statement Does the NSDL quantity agree with the company/RTA record?
CDSL demat holding Depository/RTA holding statement Does the CDSL quantity agree with the company/RTA record?
Physical holding Register of members, certificates and folio records Are legacy certificates and folio records current and supportable?
Pending demat requests RTA/depository request tracker Are older pending requests explained with reasons and ownership?

Documents And Process

The company should begin with an ISIN-wise data pack. One company may have equity shares, preference shares, debentures or other securities that need separate treatment. PAS-6 preparation should not treat every instrument as one generic security bucket.

The working file should include the latest register of members or security holders, depository holding statements, physical certificate/folio position, allotment and transfer records, changes in share capital during the half year, demat request status, pending request reasons, details of the company secretary or responsible officer, and professional certification notes.

If any record includes PAN, bank details, signatures, KYC documents, shareholder-sensitive correspondence or passwords, it should move through controlled channels. Readers should not email passwords, OTPs, unmasked bank details, signatures or full KYC packets unless a secure submission method has been provided.

Common Errors

The first error is waiting until the filing due date to ask for depository data. PAS-6 is easier when the RTA, finance team and company secretary run a half-year close checklist soon after 31 March or 30 September.

The second error is reconciling only total capital. PAS-6 is more useful when reviewed ISIN-wise and security-class-wise.

The third error is ignoring pending demat requests. Old requests can point to name mismatch, certificate mismatch, signature mismatch, transmission issues or incomplete holder documents.

The fourth error is assuming that a clean PAS-6 filing cures earlier defects. If allotment filings, transfer records, reductions, buybacks, conversions, certificates or depository balances are inconsistent, the issue should be investigated and documented.

Depository Scale Context

PAS-6 sits inside a large demat ecosystem. NSDL's statistics at a glance for 30 June 2026 reported 4,56,25,427 active client accounts and 1,15,107 companies joined. CDSL's business page for 30 June 2026 reported 18,59,20,991 investor accounts excluding closed accounts, 46,939 equity securities available for demat and 70,894 debt instruments and other eligible securities available for demat.

Selected depository indicators checked on 31 July 2026
Indicator Official value Why it matters for PAS-6
CDSL investor accounts, excluding closed accounts 18,59,20,991 Issuer records must support downstream investor servicing at scale.
NSDL active client accounts 4,56,25,427 Demat holdings should be reconciled against reliable issuer/RTA records.
NSDL companies joined 1,15,107 Company admission and ISIN records support half-year reconciliation.
CDSL equity securities available for demat 46,939 Equity ISIN data should be mapped to the correct security class.
CDSL debt instruments and other eligible securities available for demat 70,894 Non-equity instruments may need separate PAS-6 review where applicable.

How Abhipra Can Assist

Abhipra can support companies with ISIN-wise reconciliation, depository/RTA data coordination, physical-folio review, pending demat request tracking, PAS-6 working papers and half-year close planning. The company's board, company secretary, auditor and certifying professional should approve final legal applicability, form content and filing positions.

Need assistance with Rule 9A/Rule 9B applicability, ISIN activation, RTA appointment, share-capital reconciliation or corporate actions?
Contact Abhipra RTA Services at rtaservices@abhipra.com, call 011-42390783, or contact +91-9818080700.
Share the company's name, CIN, company type, latest audited financial year, security classes and approximate number of shareholders for a preliminary discussion.

PAS-6 Half-Year Close Workflow

RTA operations desk arranged with NSDL, CDSL, physical, issued-capital and certification files for PAS-6 reconciliation

The practical workflow is to freeze the half-year date, prepare the ISIN-wise security inventory, collect NSDL and CDSL balances, verify physical folios, reconcile with issued capital, investigate differences, review pending demat requests, obtain professional certification and preserve the filed form with supporting evidence.

PAS-6 half-year close workflow
Step Evidence to keep Owner to identify
ISIN-wise inventory Security class, ISIN, face value, paid-up value and issued quantity. Company secretary with RTA input.
Depository and physical reconciliation NSDL/CDSL holding data, physical folio summary and reconciliation working. RTA coordination owner.
Difference investigation Exception note, reason, supporting documents and depository intimation where required. Company secretary and finance team.
Certification and filing Professional certification trail, filed form, challan/acknowledgement and board/reporting note. Authorised signatory and certifying professional.

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Disclaimer

This article is for general educational information and does not constitute legal, tax, investment or transaction advice. Applicability depends on the company's and investor's facts and on the law, circulars and depository instructions in force on the relevant date.