Amendment of Object Clause of Memorandum

• ROC Position: Under MCA rules, expanding the main objects into regulated financial services (brokerage, portfolio management) strictly requires the company name to align with those objects.

• Without Name Change: You can resolve this by rewording the objects to specify internal/treasury investment of surplus funds only (excluding public/SEBI-regulated brokerage activities) or shifting them to Ancillary Objects.

• With Commercial Operations: If offering actual brokerage or PMS services to clients, a formal name change (via RUN and INC-24) is mandatory to obtain approval.

The Rule 10(2) name query is triggered when the ROC believes the proposed objects require a name reflecting a regulated financial activity. Three paths to resolve it:

1. REFRAME THE OBJECTS: Draft the new objects as managing the company own surplus funds through permitted financial instruments, not providing portfolio management services to clients. Portfolio Management Services (PMS) to third parties require SEBI registration and trigger the name alignment rule. Investing own treasury funds does not carry the same restriction. A redraft with this framing often removes the Rule 10(2) objection.

2. CLASSIFY AS ANCILLARY: State that the financial activities are ancillary and incidental to the main business objects, not a primary or commercial line. Many ROC offices accept this framing for activities that are supporting rather than revenue-generating.

3. ACCEPT THE NAME CHANGE (if commercially needed): If the company genuinely intends to offer brokerage or PMS to clients, a SEBI license will be mandatory regardless. In that case, a name change (adding Securities, Finserv, or Investments) removes the ROC objection and also makes the company name market-relevant.

Forms required for object clause amendment: Board resolution, EGM (special resolution), Form MGT-14 (for filing the special resolution) and Form INC-6 (if applicable) on MCA v3. This [ROC filing charges and process guide](https://taxgarden.in/blog/roc-filing-charges-2026) covers the filings, MCA fees, and timeline for object clause amendments.