Half-Year Close Calendar for Share-Capital Reconciliation

Reviewed on: 7 August 2026. Reviewed by Abhipra RTA / Compliance Team.

A PAS-6 half-year close should not start after the period has already ended. Companies that are covered by the dematerialisation framework should maintain an ISIN-wise reconciliation calendar so that the company register, RTA records, depository balances, capital changes and professional certification file are ready before the statutory filing window closes.

Company compliance team reviewing share-capital reconciliation files before PAS-6 close

Why The Half-Year Close Calendar Matters

Form PAS-6 is linked to the reconciliation of share capital in dematerialised form. The ICSI referencer records that Form PAS-6 is filed for half-yearly reconciliation of share capital and is certified by a Company Secretary in practice or Chartered Accountant in practice before submission to the Registrar of Companies. It also states that the form is to be submitted within 60 days from the conclusion of each half year.

For management, this means PAS-6 is not only an MCA filing event. It is a control cycle. The company should be able to explain whether issued capital, paid-up capital, physical holdings, dematerialised holdings with NSDL and CDSL, and security-class wise ISIN records agree with each other. If they do not agree, the difference should be investigated and documented before certification is requested.

The control is especially important because India's depository ecosystem is large and active. NSDL's latest public statistics reviewed for this article show 4,61,73,386 active client accounts as at 31 July 2026, 1,16,529 companies joined, and 43,767 companies in which more than 75% shares are dematerialised. CDSL's business page, last updated on 3 August 2026, shows investor accounts of 18,59,20,991 as at 30 June 2026 and lists issuer and ISIN details through July 2026. These figures make it clear that reconciliation must be treated as a structured data-control activity, not a last-week compilation exercise.

Applicability And Key Dates

The company should first confirm whether Rule 9A, Rule 9B or another dematerialisation requirement applies to the relevant entity and security class. Rule 9A was introduced for unlisted public companies through the MCA notification dated 10 September 2018. Rule 9B was notified through G.S.R. 802(E) dated 27 October 2023 for certain private companies, subject to its exclusions and transition periods.

The commonly used PAS-6 half-year calendar is:

Half-year period Period end Internal close target Statutory filing window
April to September 2026 30 September 2026 By 15 October 2026 Within 60 days from half-year end, normally by 29 November 2026
October 2026 to March 2027 31 March 2027 By 15 April 2027 Within 60 days from half-year end, normally by 30 May 2027

For a company that is still completing Rule 9B onboarding, the calendar should also track ISIN activation, demat connectivity, shareholder communication, capital-event restrictions and unresolved physical holdings. The 30 June 2025 special extension for certain non-producer private companies has already passed; it should be treated as a past compliance date, not as an upcoming deadline.

Documents And Process

A practical PAS-6 close calendar should allocate responsibility before the half-year ends:

Workstream Owner to coordinate Evidence to collect Why it matters
Security-class inventory Company secretarial team Equity, preference, debenture and other security-class list with ISIN status PAS-6 and demat reconciliation are generally ISIN-wise.
Capital register tie-out Company and RTA Register of members, allotment records, transfer records and board/corporate-action records Issued and paid-up capital should agree with corporate records.
Depository balance confirmation RTA / issuer operations NSDL and CDSL holding or balance reports for each ISIN Dematerialised capital must be mapped to depository records.
Physical holding review Company and RTA Folio list, certificates pending demat, rejected DRFs and mismatch notes Unresolved physical balances can explain reconciliation differences.
Change-period testing Company, RTA and professional Allotments, transfers, transmission, cancellation, split/consolidation or other capital changes during the half-year Movement during the period is often where mismatch risk enters.
Certification file Practising CS or CA Management representation, reconciled schedules, discrepancy notes and supporting evidence The professional should receive a complete review file, not unsupported summaries.

The process should normally follow this sequence: freeze the half-year cut-off data, prepare an ISIN-wise reconciliation sheet, compare company/RTA/depository balances, investigate differences, document management responses, obtain professional review comments, clear defects, and then file through the MCA process.

Common Errors

The most common mistake is preparing one company-level summary instead of an ISIN-wise reconciliation. Equity shares, preference shares, debentures, CCDs or other instruments may require separate treatment. Another recurring issue is using stale depository data or relying only on an internal register without matching NSDL and CDSL balances.

Companies should also avoid assuming that dematerialisation removes all company-law, articles-of-association or contractual transfer restrictions. Demat improves record integrity and transfer mechanics, but it does not automatically make private-company securities freely transferable.

Where Rule 9B applies to a private company, the use of the Rule 9A/PAS-6 framework for private-company filings may require professional interpretation of the current MCA form, portal behaviour and company facts. If the scope is unclear, it should be marked for company-secretarial or legal review before filing.

How Abhipra Can Assist

Abhipra can help companies and professionals structure the half-year close by coordinating RTA records, ISIN-wise data, depository connectivity information, shareholder dematerialisation status, capital-event evidence and discrepancy notes for review by the company's advisers and certifying professional.

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.

Reconciliation Close Workflow

Secure corporate records grouped for company register, depository statement and certification review

The half-year close works best when the company separates the workflow into four controls:

Control point What to verify Practical checkpoint
Cut-off control The exact half-year end date used for all data extracts Keep one approved cut-off pack for the company, RTA and professional.
ISIN control Each security class has the correct ISIN mapping Do not merge security classes merely because they belong to the same company.
Movement control All allotments, transfers, transmission cases and corporate actions during the period are captured Tie every movement to board, shareholder, RTA or depository evidence.
Difference control Any mismatch between issued capital and depository/physical balances is explained Keep ageing, owner, action plan and management response for each open item.

Depository Scale Snapshot For Management

The figures below are included to help management understand why reconciliations should be handled as a formal control cycle. They are not a measure of Abhipra's client base.

Public source reviewed on 7 August 2026 Latest data date shown by source Selected metric Published figure
NSDL statistics page 31 July 2026 Active client accounts 4,61,73,386
NSDL statistics page 31 July 2026 Companies joined 1,16,529
NSDL statistics page 31 July 2026 Companies with more than 75% shares dematerialised 43,767
CDSL business page 30 June 2026 Investor accounts, excluding closed accounts 18,59,20,991
CDSL business page 30 June 2026 Equity securities available for demat 46,939
CDSL business page 30 June 2026 Depository participants 588

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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.