Changes in Particulars of Director intimated Through DIR-6 or DIR-3 KYC - A Dilemma

CA. Anshal Khare 
on 20 August 2019


As per the Companies (Amendment and Qualification of Directors) Third Amendment Rules, 2019 those who have already filed DIR-3 KYC, would only be required to complete their Web-Based KYC, which will be pre-filled with data, based on the records present in the registry of the government, for ease of verification by such persons concerned.

Features of DIR-3 KYC

  • KYC of DIN on annual basis by 30th September is mandatory;
  • For Form DIR-3KYC. Digital Signature is required.
  • KYC of DIN in respect of which DIR-3 KYC has been made in previous years can be made by filing following forms by 30th September of respective financial year:
  • Unique Email Id and Mobile Number of Director Required which is totally different from the E Mail Id of Company which is reported through Active Form

Question: While Filling the E Form DIR-3KYC, it comes to the notice that Particulars in Name of Director or Fathers name is Different from PAN Database:

Answer: No need to worry as soon as Form DIR-3 KYC uploaded with Corrected Data, Changes automatically taken place.

Question: What about if Changes have taken place after filling Form DIR-3 KYC?

Answer: In such a case we shall need to file Form DIR-6 to MCA Portal.

Conclusion:

E Form DIR-3 KYC may be also used as reporting changes in Particulars of Director while filling of Annual Basis but if any Changes Occurred after E Filling of Form DIR-3KYC, which shall be reported through E Form DIR-6 for Intimation of change in particulars of Director to be given to the Central Government. Hence in the present scenario, while uploading Form DIR 3KYC, the objective of Form DIR-6 is also fulfilled which is create Dilemma whether to use DIR-6 before E Form DIR-3 KYC or alone file E Form DIR-3 KYC.

So only filling of E Form DIR-3 KYC is sufficient in itself.


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