MCA Form Guide
PAS-3 — Return of Allotment
Quick answer: Filed after every allotment of shares — including seed rounds, angel rounds, Series A, convertible note conversions, ESOP exercises, and rights issues. Updates the cap table on MCA records. Within 15 days of the date of allotment (date of board resolution allotting shares). ₹100/day. Late PAS-3 creates cap table inconsistencies between company records and MCA — which causes problems in due diligence and FEMA filings.
Quick answer
Capital filings tend to follow share issuances, changes in structure, or the company’s first post-incorporation steps. They matter because cap table accuracy affects everything else downstream. All companies allotting shares, convertible instruments, or any other securities to any person. 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 allotting shares, convertible instruments, or any other securities to any person.
When to file
Within 15 days of the date of allotment (date of board resolution allotting shares).
Penalty note
₹100/day. Late PAS-3 creates cap table inconsistencies between company records and MCA — which causes problems in due diligence and FEMA filings.
Filing portal
MCA portal at the official government filing system.
Evidence checklist
Shareholder approvals, allotment evidence, and capital structure records are usually needed before you file.
How to file
- 1
Confirm whether PAS-3 is the correct filing for the event you are handling and that it matches the capital filing trigger.
- 2
Collect the supporting records that match PAS-3: Shareholder approvals, allotment evidence, and capital structure records are usually needed before you file.
- 3
Prepare the form in the MCA portal, validate the entries against the company records, and make any final corrections before signing.
- 4
Upload the signed form, pay the applicable fee, and save the SRN and acknowledgement for audit tracking.
- 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 after every allotment of shares — including seed rounds, angel rounds, Series A, convertible note conversions, ESOP exercises, and rights issues. Updates the cap table on MCA records. Capital filings tend to follow share issuances, changes in structure, or the company’s first post-incorporation steps. They matter because cap table accuracy affects everything else downstream. 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 PAS-3?
All companies allotting shares, convertible instruments, or any other securities to any person.
What is the deadline for PAS-3?
Within 15 days of the date of allotment (date of board resolution allotting shares).
What happens if PAS-3 is filed late?
₹100/day. Late PAS-3 creates cap table inconsistencies between company records and MCA — which causes problems in due diligence and FEMA filings.
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 PAS-3 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 PAS-3?
Section 39(4), Companies Act 2013; Rule 12, Companies (Prospectus and Allotment of Securities) Rules 2014
Why this one matters
Open this guide whenever the shareholding stack changes, because fixing capital records later is slower and more expensive.
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