Why it matters
INC-20A is a simple form, but missing it has real consequences. Until it's filed, the company can't commence business or exercise borrowing powers, and the penalty on the company and its officers grows daily up to the cap.
The subscription money must actually be received in the company's bank account. That's why we open the bank account and collect capital immediately after incorporation.
Documents required
- Company bank statement showing receipt of subscription money from each subscriber.
- Certificate of incorporation.
- Registered office verification, where required.
How we handle it
Collect capital
Each subscriber pays for their shares into the company's account.
File INC-20A
Declaration filed with the bank statement, certified as required.
If late
Filed with additional fees, and the penalty dealt with through adjudication.
The other first-year steps
| Step | Timeline |
|---|---|
| Open a bank account and receive subscription money | Immediately after incorporation |
| Appoint the first auditor | Within 30 days of incorporation |
| First board meeting | Within 30 days of incorporation |
| Issue share certificates (or credit shares in demat form where Rule 9B applies) | Within two months of incorporation |
| File INC-20A | Within 180 days of incorporation |
| Maintain statutory registers | From incorporation |
We handle these together for every company we incorporate — see secretarial compliance.
Practical notes from our engagements
- Bank account opened late. Capital can't be shown without it. Open it within the first weeks.
- Subscriber paid from a third party's account. The money should come from the subscriber.
How we handle INC-20A
We file INC-20A for every company we incorporate, well inside the 180 days, and regularise late filings for companies that come to us afterwards.
Related services
Frequently asked questions
What is INC-20A?
A declaration by a director that every subscriber has paid for their shares, filed within 180 days of incorporation under Section 10A.
Which companies must file INC-20A?
Companies with share capital incorporated on or after 2 November 2018.
What is the penalty for not filing?
₹50,000 on the company and ₹1,000 a day on each officer in default, up to ₹1 lakh.
Can INC-20A be filed late?
Yes, with additional fees, but the penalty for the default still applies.
Can a company borrow before filing INC-20A?
No. It can't commence business or exercise borrowing powers until the declaration is filed.
Does an LLP file INC-20A?
No. INC-20A applies to companies with share capital.
Does a Section 8 company without share capital file INC-20A?
No. Section 10A applies to companies having share capital.