PAS-6 Review For Practising Company Secretaries And Chartered Accountants

Reviewed on: 6 August 2026. Reviewed by Abhipra RTA Team.

PAS-6 certification should be treated as a professional review of evidence, not a mechanical filing exercise. A practising company secretary or chartered accountant should verify applicability, ISIN-wise issued capital, NSDL and CDSL balances, physical holdings, pending demat requests, differences and the audit trail before signing or supporting the filing.

Practising company secretary, chartered accountant and RTA professional reviewing PAS-6 reconciliation workpapers

Certification Scope

For companies covered by Rule 9A, Form PAS-6 is the half-yearly reconciliation of share capital audit report. The working file should support the comparison between issued capital and securities held in dematerialised form with NSDL, securities held in dematerialised form with CDSL and securities still held in physical form.

The professional review should answer three questions. First, is the company covered for the period under review? Second, do the ISIN-wise numbers agree with source records? Third, if there is a difference, has the company identified the reason, owner, evidence and depository intimation position?

Rule 9B applies a Rule 9A-style dematerialisation framework to private companies other than small companies, subject to exemptions, timelines and company-specific facts. Private-company PAS-6 treatment should be checked against the latest MCA form, portal behaviour and professional advice. 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 6 August 2026.

Professional Review Checklist

PAS-6 professional review checklist
Review area Key question Evidence to inspect
Applicability Does Rule 9A, Rule 9B, exemption, timeline or company type affect the filing position? Company type, latest financial-year facts, small-company test where relevant, exemption note and professional conclusion.
Security master Is every security class reviewed separately? ISIN, class, face value, paid-up value, instrument terms, issued quantity and holder count.
Issued capital Does the issued quantity agree with statutory and board-approved records? Register extract, allotment records, board/shareholder approvals, filings and financial records.
Demat balances Are NSDL and CDSL balances separately verified for the same cut-off date? Dated depository statements, RTA confirmations and reconciliation working papers.
Physical holdings Is the physical balance supported and explainable? Folio summary, certificate status, lost/duplicate certificate records and transfer/transmission history.
Pending requests Are pending, rejected and queried demat requests separated from final holdings? Request ageing report, rejection/query evidence and closure notes.
Differences If totals do not agree, is the difference classified and documented? Exception note, cause analysis, owner, corrective action, depository intimation and management representation.

Red Flags Before Signing

Red flags that should be resolved before PAS-6 certification
Red flag Risk Practical response
Company register and depository statements use different dates The reconciliation may show artificial differences or hide real ones. Freeze one cut-off date and document any unavoidable timing exception.
Only a management total is provided The certifier cannot trace the number to primary evidence. Request source extracts, dated statements and ISIN-wise working papers.
Multiple security classes are combined One ISIN or instrument class may be wrong even if the company-level total looks right. Prepare separate lines for each ISIN, class, face value and paid-up value.
Pending demat requests are counted as completed holdings Actual balances may be overstated or understated. Track pending, rejected, queried and closed requests separately.
Physical certificates are not reconciled Legacy folio issues can distort the issued-versus-demat position. Review physical folio summary, certificate status and transfer/transmission history.

Review Notes For Rule 9B Companies

For private companies, the certifier should avoid a generic answer. The review should consider whether the company is a small company, when it ceased to be small if applicable, whether any special-category timeline applies, whether the security event is an issue or transfer, and whether the latest MCA form or portal route expects a filing or a supporting reconciliation record.

The professional conclusion should be dated and tied to the facts reviewed. If the position is unclear, the file should say so rather than presenting a legal assumption as settled. REQUIRES HUMAN LEGAL REVIEW.

Sensitive documents should move through controlled channels. Readers should not email passwords, OTPs, unmasked bank details, signatures, full PAN copies or complete KYC packs unless a secure submission method has been provided.

Depository Scale Context

PAS-6 certification 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 6 August 2026
Indicator Official value Certification relevance
CDSL investor accounts, excluding closed accounts 18,59,20,991 Issuer-record quality affects downstream investor-service reliability.
NSDL active client accounts 4,56,25,427 Demat balances should be traced to the right issuer security and ISIN.
NSDL companies joined 1,15,107 Issuer admission evidence supports certification and future audit review.
CDSL equity securities available for demat 46,939 Equity classes need separate reconciliation from other instruments.
CDSL debt instruments and other eligible securities available for demat 70,894 Non-equity instruments may require a separate certification evidence pack.

How Abhipra Can Assist

Abhipra can support companies and professionals with RTA register extracts, NSDL/CDSL balance coordination, ISIN-wise security masters, physical-folio summaries, pending demat request trackers, exception notes, PAS-6 working papers and certification support packs. Final certification, legal applicability, filing position and depository intimation should be approved by the company's board, company secretary, auditor 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.

PAS-6 Certification Review Workflow

RTA compliance desk with professional review papers, source records and reconciliation evidence for PAS-6 certification

A practical workflow is to confirm applicability, freeze the cut-off date, review the ISIN-wise security master, inspect issued-capital evidence, match NSDL and CDSL balances, verify physical records, age pending requests, classify differences, obtain management representation and preserve the signed review trail.

PAS-6 certification review workflow
Stage Professional action Output
Plan Confirm applicability, period, cut-off date and security classes. Review scope note.
Verify Trace issued, NSDL, CDSL, physical and pending-request numbers to source records. ISIN-wise working paper.
Challenge Review differences, unusual movements, stale requests and management explanations. Exception register and closure evidence.
Conclude Document professional conclusion, filing data and open caveats. Certification trail and archive index.

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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.