PAS-5 — Complete Filing Guide on MCA V3 Portal
PAS-5 is an MCA e-form filed under Section 42 of the Companies Act, 2013 for Record of private placement offers and acceptances maintained by company. Filed on MCA V3 portal (mca.gov.in) with DSC. Late filing attracts additional fees 2x-12x normal fee. This guide covers step-by-step filing, documents, fees, common errors, and penalties. Updated March 2026.
Section: Section 42 | Portal: MCA V3 (mca.gov.in)
Authentication: DSC mandatory | Late Fees: 2x-12x normal fee
When to File PAS-5?
PAS-5 must be filed when record of private placement offers and acceptances maintained by company. Filing deadline is typically 15-30 days from the triggering event. Missing deadlines attracts additional fees and potential penalties under the applicable section through Section 454 adjudication by ROC.
Step-by-Step Filing Process on MCA V3
Step 1 — Login to MCA V3 Portal
Go to mca.gov.in → Login with Business User credentials → Navigate to MCA Services → Company Forms. Ensure your account is active and DSC is registered.
Step 2 — Select Form and Enter CIN
Select PAS-5 from the dropdown. Enter company CIN. Form auto-populates company details from master data — verify all pre-filled information carefully.
Step 3 — Fill Form Details
Enter all required information as per the event. Key fields: date of Board resolution, details of the event, DIN of directors (if applicable), amounts and values. Cross-verify with Board minutes and supporting documents.
Step 4 — Upload Attachments
Attach mandatory documents in PDF format (max 10 MB each): certified copy of Board resolution, shareholder resolution (if SR required), professional certifications, and form-specific documents. Missing attachments cause rejection.
Step 5 — Affix DSC and Submit
Director and/or CS affixes DSC. Professional certifier (CS/CA/CMA in Practice) affixes their DSC where required. Click Submit to generate SRN (Service Request Number).
Step 6 — Pay Fee and Track
Pay prescribed fee via credit/debit card or net banking. Save SRN and payment receipt. Track status: Filed → Under Processing → Approved/Resubmission Required. Respond to ROC queries within 15 days.
Documents Required
| Document | Format | Mandatory? |
|---|---|---|
| Certified copy of Board Resolution | PDF (max 10 MB) | Yes |
| Shareholder Resolution (if SR required) | Conditional | |
| Professional Certification (CS/CA/CMA) | On form (DSC) | Where specified |
| Consent / Declaration forms | As per form type | |
| Supporting evidence / documents | Yes |
Filing Fees
| Authorized Capital | Normal Fee |
|---|---|
| Up to Rs. 1 lakh | Rs. 200 |
| Rs. 1 lakh to Rs. 5 lakh | Rs. 300 |
| Rs. 5 lakh to Rs. 25 lakh | Rs. 400 |
| Rs. 25 lakh to Rs. 1 crore | Rs. 500 |
| Above Rs. 1 crore | Rs. 600 |
Late filing: Up to 15 days = 2x | 15-30 days = 4x | 30-60 days = 6x | 60-90 days = 10x | Beyond 90 days = 12x normal fee.
Common Errors and How to Avoid Them
1. Incorrect CIN/Company Details: Pre-filled data mismatch. Solution: update master data on V3 first.
2. DSC Not Registered or Expired: Re-register DSC on V3 portal. Check validity date.
3. Attachment Size Exceeds 10 MB: Compress PDFs. Split large documents if needed.
4. Wrong Date or Resolution Number: Cross-verify with Board minutes before entering.
5. Missing Mandatory Attachment: Causes rejection. Use checklist before filing.
Penalty for Non-Filing
| Default | Company Penalty | Officer Penalty |
|---|---|---|
| Non-filing within deadline | Rs. 1L-10L + additional fees | Rs. 50,000-5L per officer |
| Filing with false information | Rs. 1L-10L | Imprisonment up to 6 months + fine (Sec 448) |
| 3-year non-filing (annual forms) | Strike-off (Sec 248) | Director disqualification 5 years (Sec 164(2)) |