File Form INC-20A -- explained: this guide covers what File Form INC-20A -- means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
What Is Form INC-20A?
Form INC-20A is an electronic form prescribed under the Companies Act, 2013 for the purpose of Declaration that subscribers have paid the value of shares agreed to be taken by them and verification of registered office. It is filed with the Registrar of Companies (ROC) through the MCA V3 Portal.
| Parameter | Details |
|---|---|
| Form Number | INC-20A |
| Purpose | Declaration that subscribers have paid the value of shares agreed to be taken by them and verification of registered office |
| Section | Section 10A |
| Applicable Rule | Rule 23A of Companies (Incorporation) Rules, 2014 |
| Who Must File | Company (through authorized director) |
| Who Must Sign (DSC) | Director + Practicing Professional (CA/CS) |
| Filing Deadline | Within 180 days of incorporation |
| Government Fee | Rs. 200 to Rs. 600 (based on authorized capital) |
| Late Filing Fee | Rs. 100 per day of delay (no maximum cap) |
| Filing Portal | MCA V3 Portal (mca.gov.in) -- Business User Login |
When Is Form INC-20A Required?
INC-20A is required to be filed under Section 10A of the Companies Act, 2013, read with Rule 23A of Companies (Incorporation) Rules, 2014. The filing obligation arises when the company undertakes the specific event or transaction covered by this form.
The form must be filed within Within 180 days of incorporation from the date of the relevant event. Failure to file within the prescribed period attracts additional fees of Rs. 100 per day of delay, with no upper cap. For delays exceeding 270 days, the company may need to seek condonation from the NCLT, which involves additional legal costs and time.
Documents and Attachments Required
The following documents must be attached while filing Form INC-20A:
- Board Resolution approving filing of INC-20A
- Bank statement showing receipt of subscription money from all subscribers
- Proof of registered office address (if not already filed)
Field-by-Field Filing Guide
The following table provides guidance on how to fill each key field in Form INC-20A:
| Field | What to Enter | Common Mistakes to Avoid |
|---|---|---|
| CIN | Auto-populated on entering CIN | Ensure company master data is up to date |
| Date of Incorporation | Auto-populated | Verify this matches your Certificate of Incorporation |
| Declaration | Confirm that every subscriber has paid the value of shares | Do not file if any subscriber has not yet paid -- this is a criminal declaration |
| Bank Account Details | Enter details of the company bank account where subscription money was received | Must be a current account in the company name |
Step-by-Step Filing Process on MCA V3 Portal
Board Resolution Draft
The following is a sample Board Resolution that may be adapted for use in connection with Form INC-20A. This draft is illustrative only and must be customized to the specific facts and circumstances of each case.
BOARD RESOLUTION FOR FILING FORM INC-20A
RESOLVED THAT pursuant to Section 10A of the Companies Act, 2013 read with Rule 23A of the Companies (Incorporation) Rules, 2014, the Board of Directors hereby confirms and declares that:
(a) every subscriber to the Memorandum of Association has paid the value of the shares agreed to be taken by him/her on the date of making this declaration;
(b) the Company has filed a verification of its registered office address with the Registrar of Companies;
and accordingly, the Board authorizes Mr./Ms. , Director (DIN: ), to file Form INC-20A with the Registrar of Companies, .
RESOLVED FURTHER THAT Mr./Ms. be and is hereby authorized to digitally sign Form INC-20A and to do all such acts, deeds, and things as may be necessary to give effect to this resolution.
Government Fees
| Authorized Capital / Turnover | Normal Fee | Additional Fee (per day delay) |
|---|---|---|
| Up to Rs. 1,00,000 | Rs. 200 | Rs. 100 |
| Rs. 1,00,001 to Rs. 5,00,000 | Rs. 300 | Rs. 100 |
| Rs. 5,00,001 to Rs. 25,00,000 | Rs. 400 | Rs. 100 |
| Rs. 25,00,001 to Rs. 1,00,00,000 | Rs. 500 | Rs. 100 |
| Above Rs. 1,00,00,000 | Rs. 600 | Rs. 100 |
Common Rejection Reasons and Fixes
The following are the most common reasons for rejection of Form INC-20A by the ROC, along with suggested remedies:
- Filed after 180 days: INC-20A must be filed within 180 days of incorporation; after that, the ROC may initiate striking off proceedings under Section 248
- Subscription money not deposited in company account: All subscription money must be deposited in the company bank account before filing
- Registered office not verified: Ensure INC-22 (registered office verification) is filed before or simultaneously with INC-20A
Penalties for Non-Filing or Late Filing
| Default | Company Penalty | Officer Penalty |
|---|---|---|
| Late filing (within 270 days) | Rs. 100/day additional fee (no cap) | May face proportionate penalty |
| Non-filing (beyond 270 days) | NCLT condonation required (Rs. 5,000-50,000 legal cost) | Director disqualification risk under Section 164(2) |
| False declaration in form | Rs. 1 lakh to Rs. 10 lakh | Imprisonment up to 6 months under Section 448-449 |