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ROC Share Allotment & Secretarial Compliance

Legally finalize your investment round with MCA and RBI. SNB Consultancy handles post-fundraising secretarial compliances including PAS-3 share allotment filings, SH-7 authorized capital expansion, MGT-14 board resolutions, and RBI FCGPR filings for foreign investors.

After funds are wired into the company bank account, the Companies Act, 2013 mandates strict 60-day deadlines for share allotment and ROC filing. Failing to file Form PAS-3 within the prescribed timeframe attracts heavy penalties and invalidates the legal title of investor shares.

Our Post-Fundraising Compliance Services Include:

  • Form SH-7 filing for increasing Authorized Share Capital to accommodate new equity/CCPS
  • Drafting Extraordinary General Meeting (EGM) notices, explanatory statements, and MGT-14 special resolutions
  • Form PAS-3 Return of Allotment filing with ROC for equity shares and Compulsorily Convertible Preference Shares (CCPS)
  • Issuance of physical / demat Share Certificates (Form SH-1) and state stamp duty payment
  • RBI FIRMS portal filing (Form FCGPR) for foreign direct investment (FDI) inward remittances

Post-Fundraising Secretarial Roadmap & Statutory Timelines

Once investment funds arrive, the following statutory steps must be executed sequentially under MCA and RBI guidelines:

Post-Investment ROC & RBI Compliance Steps

Statutory Compliance Step Form / Portal Requirement Statutory Deadline
1. Authorized Capital Increase Form SH-7 filed on MCA portal Within 30 days of passing EGM special resolution
2. Offer Letter & EGM Approval Form PAS-4 Private Placement Offer & Form MGT-14 Within 30 days of passing special resolution
3. Share Allotment Board Meeting Board Resolution approving allotment of CCPS / Equity Within 60 days of receiving investment funds
4. Return of Allotment Filing Form PAS-3 filed on MCA portal with list of allottees Within 15 days of allotment board meeting
5. Share Certificate & Stamp Duty Form SH-1 share certificates & e-Stamping via Revenue Portal Within 60 days of share allotment date
6. Foreign Investment Reporting (FDI) Form FCGPR submitted on RBI FIRMS Portal (Single Master Form) Within 30 days of share allotment date

Documents Required for Post-Fundraising Compliance

  • Bank Inward Remittance Proof: Bank AD Certificate / FIRC for foreign investors or bank credit advice for domestic funds.
  • Valuation Report: IBBI Registered Valuer DCF valuation report as of the allotment date.
  • Executed Term Sheet & SHA: Signed Share Subscription and Shareholders Agreement.

Execute Your Post-Fundraising ROC Filings

Partner with SNB Consultancy for PAS-3 allotment drafting, MGT-14 special resolutions, share certificate stamping, and RBI FIRMS portal compliance.

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