PAS-6 for April to September 2026 by 29 November: a share capital reconciliation sheet for CA firms
What you get: a ready-to-copy Google Sheet layout for the PAS-6 half-yearly share capital reconciliation for the half year 1 April to 30 September 2026. Tab 1 has one row per company client with a must-file test (unlisted public company, or private company that is not a small company), a due-date formula (29 November 2026), certifier, SRN and a status formula. Tab 2 has one row per ISIN: shares in the register of members against shares held with NSDL, CDSL and in physical form, with a difference formula that flags any gap you must explain in the form. Tab 3 filters the clients still unfiled. You also get a made-up example, a plan for 16 to 29 November and a WhatsApp message for clients.
Short answer (checked 26 Oct 2026): rule 9A(8) of the Companies (Prospectus and Allotment of Securities) Rules, 2014 asks an unlisted public company to file PAS-6, signed off by a practising company secretary or chartered accountant, within 60 days from the end of each half year. Rule 9B(5) applies the same sub-rules to private companies that must dematerialise their shares, which means every private company that is not a small company (government companies are out). Sixty days from 30 September 2026 is Sunday 29 November 2026, so aim to file by Friday 27 November. Since 1 December 2025 a small company is one with paid-up capital up to ₹10 crore and turnover up to ₹100 crore (G.S.R. 880(E)); holding or subsidiary companies and section 8 companies cannot be small companies.
Who files and who does not
- Unlisted public companies: file under rule 9A, unless the company is a Nidhi, a government company or a wholly-owned subsidiary.
- Private companies: file under rule 9B unless they are a small company or a government company. Test the small-company limits on the figures section 2(85) uses (paid-up capital, and turnover for the immediately preceding financial year).
- Companies that became small after the December 2025 change: some clients that were above ₹4 crore / ₹40 crore are now small companies. We did not find an MCA clarification on whether they stop filing PAS-6 at once, so mark them "Check" in the sheet and agree the position with the client's company secretary before you skip a half year.
- One form per ISIN: a company with equity and preference ISINs files once for each.
Tab "Clients": one row per company
| Col | Header | What goes in it |
|---|---|---|
| A | Client | Company name |
| B | CIN | From the MCA master data |
| C | Type | Public unlisted / Private / Government |
| D | Paid-up capital (₹ crore) | From the latest balance sheet |
| E | Turnover, FY 2025-26 (₹ crore) | From the profit and loss account |
| F | Holding, subsidiary or section 8? | Yes / No |
| G | Nidhi or wholly-owned subsidiary? | Yes / No (matters only for public companies) |
| H | Must file PAS-6? | =IF(C2="Government","No",IF(C2="Public unlisted",IF(G2="Yes","No","Yes"),IF(AND(D2<=10,E2<=100,F2="No"),"No: small company","Yes"))) |
| I | Number of ISINs | =COUNTIF('ISINs'!A:A,A2) |
| J | Due date | =DATE(2026,9,30)+60 (29 Nov 2026) |
| K | Signing professional (CA or CS in practice) | Name and membership number |
| L | Date filed | From the MCA challan, blank if not filed |
| M | SRN | From the challan |
| N | Status | =IF(LEFT(H2,2)="No","NOT NEEDED",IF(L2="",IF(TODAY()>J2,"LATE: file now","OPEN: file by "&TEXT(J2-2,"d mmm")),IF(L2>J2,"FILED LATE","OK"))) |
If a client moved below the limits after December 2025, overwrite column H with "Check" by hand until the position is agreed.
Tab "ISINs": one row per ISIN
| Col | Header | What goes in it |
|---|---|---|
| A | Client | Same name as Tab 1 |
| B | ISIN | From the depository letter |
| C | Security | Equity / preference |
| D | Shares in register of members on 30 Sep | From the statutory register |
| E | Held with NSDL | From the registrar and share transfer agent (RTA) or the depository statement as on 30 Sep |
| F | Held with CDSL | Same source |
| G | Physical | Shares not yet dematerialised |
| H | Difference | =D2-(E2+F2+G2) |
| I | Check | =IF(H2=0,"MATCH","GAP of "&TEXT(ABS(H2),"#,##0")&": explain in PAS-6") |
| J | Reason for gap | For example a pending demat request or a corporate action not yet credited |
Tab "Unfiled": who still has to file
Use =FILTER('Clients'!A2:N,'Clients'!H2:H="Yes",'Clients'!L2:L=""), then sort by number of ISINs so the multi-ISIN clients get the first call. Add columns for the date the RTA promised the reconciliation and the date the signing professional will sign.
Made-up example (not a real client)
"Sample Tools Private Limited" has paid-up capital of ₹12 crore and FY 2025-26 turnover of ₹85 crore. Its capital is above ₹10 crore, so it is not a small company and column H says Yes. It has one equity ISIN: 1,20,00,000 shares in the register, 1,05,00,000 with NSDL, 14,50,000 with CDSL and 50,000 physical. The difference is zero, so column I says MATCH. A second client, "Sample Foods Private Limited", has ₹3 crore capital and ₹60 crore turnover and is a subsidiary of a listed company: it cannot be a small company, so it files too. A third, ₹6 crore capital and ₹70 crore turnover with no holding company, was above the old limits but is now a small company: mark it "Check".
Plan for 16 to 29 November
- Mon 16 Nov: run the must-file test for every company client and ask each RTA for the 30 September holding position for every ISIN.
- Fri 20 Nov: fill the ISINs tab; chase any gap until there is a written reason.
- Wed 25 Nov: the signing professional reviews and signs; file on the MCA V3 portal.
- Fri 27 Nov: target day. Fill the date filed and SRN columns.
- Sun 29 Nov: legal last day. Anything unfiled moves to the Unfiled tab as LATE.
WhatsApp message to a client
"Hello, PAS-6 (the half-yearly share capital reconciliation) for April to September 2026 is due by Sunday 29 November. Please ask your RTA to send us the 30 September shareholding for each ISIN by Monday 16 November, and share the register of members. We plan to file by Friday 27 November. If the numbers do not match, we will need a reason for each gap before we can sign."
Related guides
- ROC AOC-4 and MGT-7 chase list for CA firms
- ROC late fee sheet for AOC-4, MGT-7 and LLP Form 8
- November 2026 due-date chase list for CA firms
- Director KYC: DIR-3 KYC three-year DIN register
- MSME Form 1 chase list for CA firms
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The White-Label Client Compliance Calendar for CA Firms (₹999/year) sends four quarterly packs with your firm name on the DOCX, PDF and WhatsApp image, plus national .ics/.xlsx and extension notes. Files are made after checkout (not instant). 14-day refund from when you receive the first pack. Disclosure: that is an Unadhi product. You can use this PAS-6 sheet without buying anything.
Sources
- MCA: Form PAS-6, Reconciliation of Share Capital Audit Report (half-yearly), rule 9A(8)
- MCA notification G.S.R. 880(E), 1 December 2025: small company limits ₹10 crore and ₹100 crore
- PIB, 16 December 2025: small company thresholds raised from 1 December 2025
- TaxGuru: PAS-6 for private companies under rule 9B(5) read with rule 9A(8)
This sheet is a working aid, not professional advice. Due dates and portal behaviour can change; check the MCA portal before you rely on them. Checked on 26 October 2026. Spot an error? Write to mininglife7@gmail.com.
Unadhi Guides are free, independent explainers. We correct errors as soon as we find them: write to mininglife7@gmail.com.