Why PAS-6 Is Prepared ISIN-Wise And What Data Must Match

Reviewed on: 1 August 2026. Reviewed by Abhipra RTA Team.

PAS-6 is prepared ISIN-wise because each admitted security class must reconcile separately. Equity shares, preference shares, debentures or other eligible securities can have different ISINs, face values, paid-up values, holder records and depository balances, so one combined company-level total can hide mismatches that matter for compliance and investor servicing.

Company secretary, finance executive and RTA professional reviewing an ISIN-wise PAS-6 reconciliation file

Why ISIN-Wise Filing Matters

Rule 9A requires covered unlisted public companies to facilitate dematerialisation and secure an ISIN for each type of security. Form PAS-6 then functions as the half-yearly reconciliation report that compares issued capital with securities held in demat form with NSDL, demat form with CDSL and physical form.

The practical consequence is that the reconciliation should be done for the relevant ISIN and security class, not only for the company's aggregate capital. A company may have fully paid equity shares, partly paid shares, preference shares, debentures or other instruments. Mixing them can make issued capital appear correct while one security class remains wrong.

Applicability And Key Dates

For unlisted public companies governed by Rule 9A, PAS-6 is filed within 60 days from the conclusion of each half year. The working half-year dates are 31 March and 30 September, usually tracked to 30 May and 29 November respectively, subject to MCA portal availability, holidays and any specific relaxation.

Rule 9B applies to private companies other than small companies, subject to exemptions and timelines. Because Rule 9B uses the Rule 9A framework mutatis mutandis, private-company PAS-6 treatment should be checked 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 1 August 2026.

What Must Match ISIN-Wise

Data fields that should match before PAS-6 is certified
Field What to compare Why mismatch matters
Security class and ISIN ISIN master, depository records, register and company approvals. A wrong class can make equity, preference or debt records appear combined.
Issued capital Register, allotment records, filings, board approvals and financial statements. Issued quantity is the base against which demat and physical holdings are checked.
NSDL demat quantity NSDL/RTA holding statement and issuer records. Depository balance should agree with the admitted security class.
CDSL demat quantity CDSL/RTA holding statement and issuer records. CDSL balance should not be merged with another ISIN or class.
Physical quantity Register of members, physical certificates and folio summary. Legacy physical records explain the portion not yet dematerialised.
Pending demat requests RTA/depository request register and ageing tracker. Long-pending requests may signal document, holder or certificate issues.

Documents And Process

The company should begin with a security-class master. This should list every ISIN, instrument type, face value, paid-up value, issued quantity, holder count, RTA record owner and depository admission status.

The next step is to collect depository balances and physical holdings for the same cut-off date. If the half-year ends on 30 September, the reconciliation should not mix a September company register with October depository data unless the exception is clearly documented.

The working papers should then compare issued quantity, NSDL quantity, CDSL quantity and physical quantity. If the totals do not agree, the team should identify whether the reason is an allotment update, transfer, demat request, transmission, corporate action, certificate issue, depository update, classification error or historic register gap.

Common Errors

The first error is using one spreadsheet for all securities without a clear ISIN column. That approach is weak where the company has more than one class or instrument.

The second error is reconciling face value but not quantity. PAS-6 review should preserve both the number of securities and the capital value because a face-value or paid-up-value mismatch can change the interpretation.

The third error is ignoring physical folios because the company has already started dematerialisation. Physical records remain relevant until the admitted security is fully reconciled.

The fourth error is treating a depository difference as a presentation issue. Rule 9A specifically expects differences between issued capital and capital held in dematerialised form to be brought to the notice of the depositories.

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 reason ISIN-wise precision matters is scale. 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 1 August 2026
Indicator Official value PAS-6 relevance
CDSL investor accounts, excluding closed accounts 18,59,20,991 Issuer/RTA data quality affects a large downstream service base.
NSDL active client accounts 4,56,25,427 Depository balances should be matched to the right issuer security.
NSDL companies joined 1,15,107 Company admission and ISIN records support half-year reconciliation.
CDSL equity securities available for demat 46,939 Equity securities need their own ISIN-wise review.
CDSL debt instruments and other eligible securities available for demat 70,894 Non-equity securities may need separate matching and certification review.

How Abhipra Can Assist

Abhipra can support companies with ISIN-wise security-class mapping, NSDL/CDSL holding data coordination, physical-folio summary, pending demat request tracking, exception notes, PAS-6 working papers and RTA evidence trails. 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.

ISIN-Wise PAS-6 Matching Workflow

RTA operations desk arranged for matching NSDL, CDSL, physical, issued-capital and exception files for PAS-6

The practical workflow is to freeze the half-year date, list every ISIN and security class, collect NSDL and CDSL balances, verify physical folios, compare the total with issued capital, investigate differences, age pending demat requests, obtain professional certification and preserve the filed form with supporting records.

ISIN-wise PAS-6 matching workflow
Step Evidence to keep Control owner
Security master ISIN, class, face value, paid-up value, issued quantity and holder count. Company secretary with RTA input.
Depository balances NSDL and CDSL holding statements for the same cut-off date. RTA coordination owner.
Physical balance Folio summary, certificate status and register extract. Company/RTA records team.
Exception resolution Difference note, pending request tracker, depository intimation and professional review. Company secretary 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.