Mca amnesty 2026

There is a pvt ltd company incorporated on 4 may 2018 and hasn't done any compliances post incorporation. No bank account has been opened as INC 20A was not applicable prior to November 2018. Not even subscripttion money received. The original subscribers are not traceable. The company is still active. New directors were appointed via DIR 12 on 16 aug 2024 and 16 may 2025 respectively and old directors were removed on the same respective dates. Now the new directors want to file all the pending roc compliances i. e. ADT 1, AOC 4, MGT 7A. 

My doubts are - 

1. Can I file them without receiving the subscripttion money or should I receive the subscripttion money in cash. 

2. When can I show the transfer of shareholding? Before receiving subscripttion money or after. 

3. Can the current directors sign the documents for FY 18-19 to 23-24?

Please help and guide. 

Replies (2)
Quick Summary
For MCA compliance backlog, first regularise share capital by receiving subscription money and completing allotment. Share transfer can occur only after allotment. Current directors can sign past filings before submitting pending ROC forms.

Before filing pending ROC compliances, you must regularise share capital (subscripttion money & allotment) because filings without it may be invalid. Share transfer can happen only after proper allotment, and current directors are allowed to sign past financials. The case requires careful structuring, not just form filing.

  • ❌ Don’t file blindly without fixing share capital
  • ✔ First regularise subscripttion/allotment
  • ✔ Then file pending ROC forms
  • ✔ Current directors can sign past filings

How to regularise the subscripttion and allotment? 

Leave a Reply

Your are not logged in . Please login to post replies

Click here to Login / Register  

Company
09 September 2026
Semi Qualified CA / CA Inter - 2 Groups Cleared

Getmyca Consultant Pvt Ltd

New Delhi

CA Inter

View Details
Company
ARTICLESHIP 07 September 2026
Article/ Paid Assistant

Murali and Sumeet Chartered Accountant

Bengaluru

CA Foundation

View Details
Company
ARTICLESHIP 24 August 2026
Article Assistant

M/s.S.G.Salecha & Co.

Mumbai

CA Inter

View Details
Company
Featured 19 August 2026
Chartered Accountant

apricus india

Pune

CA

View Details
Company
21 August 2026
Accountant

A G International

Kolkata

B.Com

View Details
Company
Featured 12 September 2026
Assistant Manager - Finance & Compliance

Naveen Fintech Pvt Ltd

Kolkata

CA Inter

View Details
Company
17 August 2026
Chartered Accountant with US GAAP Experience

Austin Med Solutions Pvt Ltd

Bengaluru

CA

View Details
Company
ARTICLESHIP 17 August 2026
CA Article Trainee

ASC Group

Noida

CA Inter

View Details