Company · Debt & charges
We're issuing debentures — what gets registered?
The short answer
Issuing debentures triggers charge registration, allotment reporting, and resolution filing — not just a board note. CHG-9 registers the charge on debentures within 30 days of creating the debenture trust deed or charge under Section 77(3). PAS-3 reports the allotment within 15 days, MGT-14 covers the resolution within 30 days, and secured or public issues need a debenture trust deed with a trustee under Section 71.
What gets filed with MCA
Within 30 days of the creation of the debenture trust deed or charge.
Section 77(3), Companies Act 2013
Within 15 days of the date of allotment (date of board resolution allotting shares).
Section 39(4), Companies Act 2013; Rule 12, Companies (Prospectus and Allotment of Securities) Rules 2014
Within 30 days of passing the resolution.
Section 117, Companies Act 2013
The paperwork nobody tells you about
Statutory formats that never touch the MCA portal — but an ROC inspection or due diligence will ask for every one of them.
Required for secured debentures / public issues; trustee appointed
Section 71, Companies Act 2013
The sequence
- 1Pass board and, where required, shareholder resolutions authorising the debenture issue
- 2Execute the debenture trust deed and appoint a trustee for secured or public issues
- 3File CHG-9 within 30 days of creating the debenture trust deed or charge
- 4File PAS-3 within 15 days of the date of allotment
- 5File MGT-14 within 30 days of passing the resolution
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Questions founders actually ask
Which form registers the debenture charge?
CHG-9 — charge on debentures. It is due within 30 days of the creation of the debenture trust deed or charge, under Section 77(3).
When is the allotment reported to MCA?
PAS-3 — return of allotment — within 15 days of the date of allotment, which is the date of the board resolution allotting the securities, under Section 39(4).
Do we always need a debenture trust deed?
A debenture trust deed is required for secured debentures and public issues, with a trustee appointed, under Section 71. Unsecured private issues may follow a lighter documentation path.
Reviewed by Harun Raaj, Chartered Accountant
Founder, Harun Raaj & Associates. Last verified 2026-08-24 against MCA V3 records and ICSI reference material. Form-level deadlines and penalties live on the linked form pages and update there.