Records To Obtain From The RTA And Depositories Before PAS-6 Certification

Reviewed on: 5 August 2026. Reviewed by Abhipra RTA Team.

Before PAS-6 certification, the company should collect records from the company register, RTA, NSDL, CDSL and physical-folio file for the same cut-off date. The purpose is not only to fill a form; it is to preserve an audit trail showing how issued capital, demat holdings, physical holdings and pending requests were verified.

Company secretary, practising professional and RTA executive reviewing PAS-6 certification records in a corporate office

Why The Record Pack Matters

Form PAS-6 is a reconciliation of share capital audit report. For companies covered by Rule 9A, 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 certifying professional should not have to rely on an unsupported management number. A useful PAS-6 pack links each number to a dated source record, identifies differences, captures pending demat requests and preserves the basis for any depository intimation.

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 5 August 2026.

Core PAS-6 Record Checklist

Records to obtain before PAS-6 certification
Record set Who should provide it What to verify
Issued capital and security master Company secretary or authorised company officer. ISIN, security class, face value, paid-up value, issued quantity, holder count and latest authorised approvals.
RTA register extract RTA records team. Register of members or debenture holders, class-wise holdings, folio status and service-request changes.
NSDL holding statement RTA/depository coordination owner. ISIN-wise NSDL demat balance for the same cut-off date used in the PAS-6 working file.
CDSL holding statement RTA/depository coordination owner. ISIN-wise CDSL demat balance for the same cut-off date used in the PAS-6 working file.
Physical folio and certificate summary Company/RTA physical records owner. Physical quantity, certificate status, duplicate/lost certificate cases, transfer/transmission history and folio exceptions.
Pending demat request tracker RTA operations owner. Pending, rejected, queried and closed requests, including ageing and reason codes where available.
Difference and exception note Company secretary with RTA and professional input. Reason for mismatch, owner, corrective action, depository intimation and professional conclusion.

Cut-Off Date Control

The most important control is the cut-off date. If the company register is dated 30 September, NSDL data is dated 1 October and CDSL data is dated 3 October, the reconciliation may show an artificial mismatch. Before certification, the team should list every source record and confirm the date to which it relates.

The same logic applies to corporate actions and service requests. An allotment, split, consolidation, conversion, transfer, transmission, remat or demat rejection can change balances. The PAS-6 file should explain whether the event is before, on or after the cut-off date.

Professional Review Matrix

Professional review points before signing or filing PAS-6
Review point Why it matters Evidence expected
Applicability The company must know whether Rule 9A, Rule 9B, exemption, timeline or special fact changes the filing position. Applicability note, company type, small-company test where relevant and professional review.
ISIN-wise structure One company may have more than one security class, ISIN, face value or paid-up value. Security master and depository admission records.
Issued capital source PAS-6 numbers should agree with statutory and board-approved records. Register extract, allotment records, filings, board/shareholder approvals and financial records.
Demat balances NSDL and CDSL balances should be separately identified and not merged into one unsupported number. Dated NSDL and CDSL statements or RTA confirmations.
Physical and pending records Physical certificates and pending demat requests often explain differences. Physical folio summary, request ageing report, rejection/query evidence and closure notes.

Common Collection Errors

The first error is asking for only a final total. A final total is not enough for professional review unless it can be traced to the source records.

The second error is mixing multiple dates. PAS-6 certification should not compare a current RTA register with old depository statements unless the exception is deliberately explained.

The third error is ignoring physical records because dematerialisation has started. Physical holdings remain part of the reconciliation until they are properly converted, cancelled, resolved or otherwise accounted for.

The fourth error is treating pending demat requests as final holdings. Pending, rejected and queried requests should be tracked separately from actual balances.

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

The PAS-6 record pack 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 5 August 2026
Indicator Official value PAS-6 record relevance
CDSL investor accounts, excluding closed accounts 18,59,20,991 Issuer and RTA records should be precise because they feed downstream investor service data.
NSDL active client accounts 4,56,25,427 Dated depository balances should map to the correct 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 records need separate class-wise reconciliation.
CDSL debt instruments and other eligible securities available for demat 70,894 Non-equity instruments may require their own ISIN-wise evidence pack.

How Abhipra Can Assist

Abhipra can support companies 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 professional-certification support packs. Final legal applicability, certification wording, 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 Record Workflow

RTA operations desk with organized record stacks for issuer approvals, depository balances, physical folios and certification evidence

A practical workflow is to confirm applicability, freeze the cut-off date, prepare the ISIN-wise security master, collect RTA records, collect NSDL and CDSL balances, verify physical folios, list pending requests, investigate differences, obtain professional review and preserve the final evidence pack.

PAS-6 certification record workflow
Stage Record output Control owner
Scope Applicability note, cut-off date and security-class list. Company secretary with professional input.
Collect RTA register extract, NSDL statement, CDSL statement and physical folio summary. RTA/depository coordination owner.
Reconcile Issued, NSDL, CDSL, physical and pending request working paper. Company/RTA reconciliation team.
Certify Exception note, professional review trail, final form data and archive index. Certifying professional and authorised company officer.

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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.