Verification of office address

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seema singla (Querist)
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27 December 2018 The Companies (Amendment) Ordinance 2018 has reintroduced the concept of Certificate of Commencement of Business. Under the new Ordinance, no company will be entitled to commence its operations except by filing a declaration within 180 days of its incorporation stating that the subscribers to the Memorandum of the company has paid the value of shares so agreed by them, and files a verification of its registered office address with the Registrar of Companies (ROC) within 30 days of its incorporation. Non-compliance with this provision will result in the removal of the company’s name from the Registrar of Companies. As far as Certificate of commencement of business, form is yet to be prescribed for filing declaration by directors u/s 10A. The second part- verification of its registered office address..within 30 days of its incorporation. (How it is to be done as Form INC-22 is for change in registered office of an existing company) .
There is no column for verification of office address.

Plz reply.
Thanx

Bhaskaran Chackrapani Warrier

Bhaskaran Chackrapani Warrier (Expert)
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27 December 2018 1. Form is INC 20A. per notification dated 18.12.2018.

2, INC 22 has to be filed, see section 12(2) and the wordings 'verification' used
therein.

seema singla

seema singla (Querist)
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27 December 2018 Thanx for reply Sir.
But in Form INC 22, It asks for purpose of the form in which options are change in office address.
No verification given.
What to do I don't understand.

Asha Kanta Sharma

Asha Kanta Sharma (Expert)
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03 August 2025 You're absolutely right to point out the confusion that arose in 2018 after the Companies (Amendment) Ordinance, 2018 was introduced. It reinstated the requirement for Certificate of Commencement of Business and verification of registered office address within specified timelines.
Let me walk you through the correct procedural requirements, as clarified by MCA following the amendment.

✅ 1. Filing Declaration of Commencement of Business – Form INC-20A
Applicable Section: Section 10A of the Companies Act, 2013 (inserted via the Amendment).
Form: INC-20A
Timeline: Within 180 days of incorporation.
Purpose: Declaration that:
Every subscriber has paid the value of the shares agreed upon, and
The company has a registered office that has been verified under Section 12(2).
So, INC-20A indirectly links to the requirement to verify the registered office under Section 12(2).
✅ 2. Verification of Registered Office – Form INC-22
Applicable Section: Section 12(2) of the Companies Act, 2013
Form: INC-22
Timeline: Within 30 days of incorporation.
🧾 What’s important to understand:
Though INC-22's dropdown originally only showed “change of address”, MCA clarified that the same form is to be used for initial verification of registered office as well.
When filing INC-22 within 30 days of incorporation, it serves as "verification" of office address under Section 12(2), not as a change.
✅ So, the form itself is used both:
For initial verification within 30 days post-incorporation, and
For change in address later.
📌 MCA Notification Reference:
Companies (Incorporation) Fourth Amendment Rules, 2018 (notified on 18 Dec 2018)
Specifically inserted Rule 23A for Form INC-20A.
Reiterated Section 12(2) compliance for INC-22.
🔁 So, the updated compliance flow post-incorporation is:
Compliance Form Timeline
Verification of registered office address INC-22 Within 30 days of incorporation
Declaration of commencement of business INC-20A Within 180 days of incorporation
🛠️ What You Should Do:
File INC-22 within 30 days of incorporation:
Select option that reflects “verification” (updated forms now reflect this).
Attach proof: e.g., utility bill, NOC from owner, rent agreement, etc.
File INC-20A once INC-22 is filed and share capital is paid.
⚠️ Penalty for Non-Compliance:
Company may be struck off under Section 248.
Directors may face penalty of ₹50,000, and company ₹50,000.
✅ Final Clarification:
Yes, Form INC-22 is correct for verification even though it earlier appeared to only allow change of address. MCA later clarified this use.

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