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Form INC-20A

Declare your Commencement of Business, correctly and on time.

Form INC-20A is the mandatory e-form every company with share capital, incorporated on or after 2nd November 2018, must file with the Registrar of Companies (ROC) under Section 10A of the Companies Act, 2013. It is a formal declaration by a director confirming that all subscribers to the memorandum have paid their subscription money and that the company's registered office has been verified — the legal green light that lets your company actually start doing business.

The deadline is strict: 180 days from the date of incorporation. Miss it, and the consequences aren't just paperwork — they include a fixed penalty on the company, daily penalties on every officer in default, an "Active Non-Compliant" flag on the MCA master data, and in persistent cases, a strike-off initiated by the Registrar. That's why most founders get this filing handled by a professional rather than risking a missed step.

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Form INC-20A
Commencement of Business Tracker
Section 10A · Companies Act, 2013
Company IncorporatedCertificate of Incorporation issued by the ROC
Subscription Money ReceivedSubscribers deposit share capital in the company's bank account
Bank & Office VerifiedBank statement and registered office proof collected
Form INC-20A FiledDeclaration submitted within 180 days of incorporation
Commencement Certified
At A Glance

The commencement journey, mapped in one flow

Form INC-20A doesn't sit in isolation — it's one checkpoint in a short, time-bound sequence that starts the moment your company is incorporated. Here's how the pieces connect.

Incorporation

Certificate of Incorporation issued

180-Day Window

Statutory clock starts running

Funds Deposited

Subscribers pay subscription money

Office Verified

Registered office proof confirmed

INC-20A Filed

Declaration submitted to the ROC

Business Commences

Company can legally start operations

Applicability

Does your company need to file Form INC-20A?

Applicability depends on your date of incorporation, entity type, and whether the company has share capital. Here's how the rule applies across common structures.

Private Limited Company

Incorporated on or after 2 Nov 2018 with share capital — must file INC-20A within 180 days before commencing any business activity or exercising borrowing powers.

Mandatory

Public Limited Company

Subject to the same Section 10A obligation as private companies — the declaration is required before public fundraising or business operations begin.

Mandatory

One Person Company (OPC)

An OPC with share capital falls squarely within Section 10A and must file its declaration within the same 180-day statutory window.

Mandatory

Company Limited by Guarantee

If the company also has share capital and was incorporated after the cut-off date, the commencement declaration still applies in full.

Mandatory

Section 8 Company (Non-Profit)

Non-profit companies licensed under Section 8 are specifically exempted from filing Form INC-20A, regardless of incorporation date.

Exempt

Companies Without Share Capital

Section 10A applies only to companies having a share capital — entities incorporated without one fall outside this filing requirement.

Exempt

Companies Incorporated Before 2 Nov 2018

The commencement-of-business declaration was reintroduced only for companies incorporated on or after this date — older companies are unaffected.

Not Applicable

Regulated Sector Companies

Banking, NBFC, insurance, and similar regulated entities must additionally attach proof of sectoral regulatory registration along with Form INC-20A.

Mandatory
The Process

From incorporation to declaration, in eight steps

Here's exactly what happens between the day your company is incorporated and the moment Form INC-20A is accepted by the Registrar of Companies.

1

Open a Company Bank Account

A current account is opened in the company's name — the destination for every subscriber's share subscription payment.

2

Subscribers Deposit Subscription Money

Every subscriber to the memorandum transfers their agreed share capital into the company's bank account via traceable banking channels.

3

Obtain Bank Statement as Proof

A statement evidencing the credited subscription amount is collected — this is the primary attachment to Form INC-20A.

4

Verify Registered Office Address

Ownership or rental proof of the registered office is confirmed, satisfying the office-verification limb of Section 10A.

5

Collect Sectoral Approval, If Applicable

Companies in regulated sectors — banking, NBFC, insurance — attach their regulator's registration certificate alongside the declaration.

6

Prepare the Board Resolution

A board resolution authorising a director to sign and file the declaration is passed and documented.

7

File Form INC-20A with DSC

The e-form is filed on the MCA portal, digitally signed by the authorised director and certified by a practising professional.

8

Receive SRN & Commencement Confirmation

Once approved, the ROC updates your company's status — you now hold formal confirmation that business can legally commence.

Eligibility

What has to be true before you can file INC-20A

Filing isn't just a formality — the ROC checks that these underlying conditions are genuinely satisfied before accepting the declaration.

Incorporated On or After 2 Nov 2018

Section 10A applies only to companies incorporated on or after this date — it does not apply retroactively to older companies.

Company Has Share Capital

The obligation is triggered only for companies incorporated with a share capital, whether private, public, or one-person.

Subscription Money Fully Received

Every subscriber named in the memorandum must have paid their full agreed share value into the company's bank account.

Registered Office Verified

The company must be able to establish that it has a verifiable registered office as declared at the time of incorporation.

Active Director DSC

At least one director must hold a valid, unexpired Digital Signature Certificate to sign and certify the e-form.

Sectoral Registration, Where Required

Companies in RBI, SEBI, or IRDA-regulated activities must first secure the relevant regulatory approval before filing.

Paperwork

Documents you'll need to keep handy

Gathering these upfront is the single biggest thing you can do to file Form INC-20A smoothly, well within the 180-day window.

Bank Account Statement

Proof that subscription money has been credited

Board Resolution

Authorising a director to sign the declaration

Certificate of Incorporation

Basic proof of the company's legal existence

NOC from Property Owner

If the registered office premises are rented

Sectoral Regulator Certificate

RBI, SEBI, or IRDA approval, where applicable

Digital Signature Certificate

Of the director filing and certifying the form

Subscribers' Payment Proof

Cheque, NEFT, or RTGS records of each subscriber

MOA & AOA

Reference documents listing the subscriber shareholding

Why It's Worth It

What filing on time actually protects you from

Form INC-20A isn't glamorous, but filing it correctly and within 180 days keeps your company operating without friction.

Avoid Heavy Penalties

Sidestep the ₹50,000 company fine and daily officer penalties

No "Active Non-Compliant" Tag

Keeps your MCA master data clean for future filings

Legally Commence Business

Unlocks the right to trade, invoice, and operate fully

Unrestricted Bank Operations

Operate accounts and access credit without compliance flags

Valid, Enforceable Contracts

Enter agreements with confidence in your legal standing

Avoid Strike-Off Risk

Reduces grounds for ROC action under Section 248

Clean Director Record

Protects directors from disqualification for repeat defaults

Investor & Lender Confidence

A clean compliance record signals a well-run company

Non-Compliance Risk

What happens if Form INC-20A isn't filed on time

Section 10A carries real teeth — here's the escalating consequence if the 180-day deadline is missed.

Penalty on the Company

A fixed penalty of ₹50,000 is levied on the company for failing to file within 180 days.

Penalty on Every Officer in Default

₹1,000 per day of default, capped at ₹1,00,000 per officer, applied to every director responsible for the delay.

"Active Non-Compliant" Status

The MCA portal flags the company, which can block or delay other statutory filings until it's resolved.

Risk of Strike-Off

The Registrar may initiate removal of the company's name under Section 248 if the declaration remains unfiled.

Blocked Business Activities

The company cannot legally commence business or exercise any borrowing powers until the declaration is filed.

Director Disqualification Risk

Repeated or prolonged defaults can be counted against a director's compliance record across other companies.

Why Hisho & Kanri

INC-20A filings handled by people who track every deadline

We track the 180-day clock for every client the moment incorporation happens, so the declaration is filed well before it becomes a compliance risk.

Company Secretaries & CAs

Qualified professionals who certify and file INC-20A declarations regularly.

Fast Turnaround

Bank proofs and office verification reviewed quickly, with no deadline surprises.

Fixed, Transparent Fees

One clear price for the filing — no hidden charges or last-minute add-ons.

Deadline Tracking

We monitor your 180-day window proactively and alert you well before it closes.

Dedicated Support

One point of contact from document collection through to ROC acceptance.

Secure Documentation

Bank statements and company records handled under strict confidentiality.

FAQ

Common questions about Form INC-20A

Can't find your question here? Use the form alongside this page and we'll answer it directly.

It's the Declaration of Commencement of Business, filed under Section 10A of the Companies Act, 2013, confirming subscribers have paid their subscription money.

Every company with share capital incorporated on or after 2 November 2018, including private, public, and one-person companies.

Within 180 days from the date of incorporation — there's no extension built into the standard filing window.

The company faces a ₹50,000 penalty, officers face ₹1,000/day penalties up to ₹1,00,000 each, and the ROC may eventually initiate strike-off.

No, Section 8 non-profit companies are specifically exempted from this filing requirement.

There's no routine extension mechanism — companies expecting delays should still file as close to the deadline as genuinely possible to limit penalty exposure.

A bank statement proving subscription payment, and a sectoral regulator certificate where the company operates in a regulated sector — see the Documents section above.

A practising Chartered Accountant, Company Secretary, or Cost Accountant must certify the form before it's filed by an authorised director.

Yes — the filing director must have an active DIN and valid Digital Signature Certificate for the declaration to be accepted.

No, the company cannot legally commence business or borrow funds until the declaration is filed and accepted by the ROC.

Because we track your 180-day deadline proactively, prepare the right proofs, and file correctly the first time, avoiding penalties entirely.