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MCA Form Guide

BEN-2Significant Beneficial Owner — Return by Company

Quick answer: Filed by the company with the ROC after receiving BEN-1 declarations. Reports all significant beneficial owners to the ROC. Within 30 days of receiving the BEN-1 declaration from the SBO. ₹10,000 company penalty + ₹1,000/day for continuing default. Officers in default: ₹10,000 + ₹1,000/day.

Annual filingIf the due date is tied to the AGM, plan backward from the board calendar so the filings do not bunch up at the end.
Recurring filingSection 90(4), Companies Act 2013

Quick answer

This is the kind of filing that sits inside the yearly compliance rhythm. A practical approach is to prepare the support pack once, then reuse it for the next cycle. All companies (except certain exempted entities) that receive BEN-1 declarations from their SBOs. For most founders, the fastest way to stay compliant is to map the filing trigger, gather the documents once, and then submit with the correct digital sign-off.

Who must file

All companies (except certain exempted entities) that receive BEN-1 declarations from their SBOs.

When to file

Within 30 days of receiving the BEN-1 declaration from the SBO.

Penalty note

₹10,000 company penalty + ₹1,000/day for continuing default. Officers in default: ₹10,000 + ₹1,000/day.

Filing portal

MCA portal at the official government filing system.

Evidence checklist

Financial statements, board approvals, and prior-year records usually matter most here.

How to file

  1. 1

    Confirm whether BEN-2 is the correct filing for the event you are handling and that it matches the annual filing trigger.

  2. 2

    Collect the supporting records that match BEN-2: Financial statements, board approvals, and prior-year records usually matter most here.

  3. 3

    Prepare the form in the MCA portal, validate the entries against the company records, and make any final corrections before signing.

  4. 4

    Upload the signed form, pay the applicable fee, and save the SRN and acknowledgement for audit tracking.

  5. 5

    Store the filing evidence with your statutory records so the next cycle is faster and easier to review.

What this form is used for

Filed by the company with the ROC after receiving BEN-1 declarations. Reports all significant beneficial owners to the ROC. This is the kind of filing that sits inside the yearly compliance rhythm. A practical approach is to prepare the support pack once, then reuse it for the next cycle. The purpose is usually either annual disclosure, a one-off event filing, or a statutory update tied to corporate records or regulatory reporting.

FAQ and compliance context

Who usually files BEN-2?

All companies (except certain exempted entities) that receive BEN-1 declarations from their SBOs.

What is the deadline for BEN-2?

Within 30 days of receiving the BEN-1 declaration from the SBO.

What happens if BEN-2 is filed late?

₹10,000 company penalty + ₹1,000/day for continuing default. Officers in default: ₹10,000 + ₹1,000/day.

Can the filing be tracked after submission?

Yes. Keep the SRN, acknowledgement, and final uploaded PDF in your records for audit and ROC follow-up.

Is BEN-2 a one-time or recurring filing?

This is a recurring filing — it must be filed every year (or every half-year / quarter, as specified) as long as the company remains in existence and meets the applicability criteria.

Which law or rule requires BEN-2?

Section 90(4), Companies Act 2013

Why this one matters

If the due date is tied to the AGM, plan backward from the board calendar so the filings do not bunch up at the end.

Related resources

Pair the filing guide with the deadline calendar and the forms hub.