INC-20A catches every company with share capital incorporated on or after 2 November 2018. It does not catch an LLP. It does not catch a Section 8 company set up without share capital. A private limited company at Hinjawadi, a one person company in Kothrud and a subsidiary that has just taken a floor at Kharadi are all inside it. Each has 180 days from the date on its incorporation certificate. Miss that date and the company is not merely late. It is barred from trading and from borrowing until the form is on record.
Does INC-20A apply to your company, and from which incorporation date?
The cut off is 2 November 2018. Any company registered on or after that date, if it has share capital, files the declaration once in its life. Public and private both file, and so does a one person company. A company limited by guarantee with no share capital does not.
Section 10A is blunt about what the declaration actually says. Every subscriber has paid the amount written against their name in the memorandum, that money sits in the company's own bank account, and the registered office has been verified with the Registrar. Nothing softer satisfies it. A promise that the capital arrives next quarter is not a declaration.
What do you have to put in front of us first?
Every item on this list is a document, not a description of one.
- The certificate of incorporation, because the 180 days run from the date printed on its face
- A bank statement or credit advice showing each subscriber's money inside the company's own account, in the amount the memorandum records against that subscriber
- Proof of the registered office at your Pune address, and where the premises are held on licence, the registered agreement for them
- A live digital signature for the director who will sign, correctly mapped on the MCA portal
- The DIN of every director on the board, with KYC done for the year
- A sectoral regulator's approval where the objects need one before business can lawfully begin
Leave and licence agreements are compulsorily registrable in Maharashtra under section 55 of the Maharashtra Rent Control Act 1999, so a Kharadi or Baner office held on licence should already have a registered agreement sitting in the file. Two problems cause most of the delay we see. Subscription money that lands in a director's personal account is not money received by the company. And a digital signature that expired quietly in December is discovered on the morning the form is due.
Which deadlines run alongside the 180 day INC-20A window?
Three clocks start on the day of incorporation, and only one of them is INC-20A.
| What is due | When it is due |
|---|---|
| Subscription money credited to the company's own bank account | Before any director signs the declaration |
| Verification of the registered office in Form INC-22 | Within 30 days of incorporation |
| Form INC-20A with the bank proof attached | Within 180 days of incorporation |
| Profession tax enrolment and registration for a new Maharashtra company | At incorporation, with the PTEC year closing on 31 March |
That last row is the one national guides skip. A Maharashtra company takes both profession tax certificates at incorporation, PTEC as its own liability at ₹2,500 a year and PTRC for the staff it puts on the books. The MCA fee for the form itself runs off authorised share capital, so two companies filing the same declaration on the same day can pay different amounts.
What does a late or missed INC-20A actually cost?
| Default | What it costs | How it runs |
|---|---|---|
| The company | ₹50,000 | One flat penalty, not a daily one |
| Each officer in default | ₹1,000 a day | Capped at ₹1,00,000 for each of them |
| The business itself | No trading and no borrowing powers | Until the form is taken on record |
| The company's name | Removal proceedings by the Registrar | Where the Registrar believes business never began |
Founders consistently underestimate the daily figure. Two directors sitting on an unfiled declaration for four months are each carrying ₹1,000 for every one of those days, with the company's own ₹50,000 stacked on top. We usually meet this at a diligence rather than at incorporation.
Adjudication of the penalty runs through the Registrar. An appeal against an adjudication order goes to the Regional Director, and for a Pune company that is Western Region Directorate II, headquartered at Navi Mumbai. If the name has already gone, restoration is not an ROC Pune application at all. It is a petition to the NCLT Mumbai Bench. There is no NCLT bench at Pune, and company matters from across the state are heard there.
From the signature to the SRN, step by step
- The incorporation certificate is read first, the last day of the 180 is fixed, and you are told how many working days genuinely remain.
- We match every credit in the bank statement against the subscription table in the memorandum, subscriber by subscriber, and raise anything short.
- We check each director's DSC and DIN, and flag a KYC that has not been done before the form is even opened.
- The signing director affixes the digital signature and we upload the form with its bank attachment on the MCA portal.
- The SRN comes back on submission, and we hold the approval and the payment challan for your statutory records.
Where a query comes back from the reviewing office, we answer it. That is part of the fee, not an extra.
Which Pune companies get caught by INC-20A?
- SaaS founders at Hinjawadi inside the Rajiv Gandhi Infotech Park, who incorporate early to sign a first customer and then leave the bank account empty for a quarter
- Corporate services offices at Kharadi that took a floor on leave and licence, and want the registered office papers clean before the declaration goes in
- Subsidiaries of foreign parents, where the subscription money is still moving through an inward remittance while the 180 days run
- Companies incorporated to bid for work at Chakan or Talegaon that have not opened for business yet
The pattern is identical in all four. The company exists, the founders are busy, and nobody has told them the clock started at incorporation rather than at the first invoice.
Which registrar receives it, and who reviews it later?
A company whose registered office is in Pune district files with ROC Pune. February 2026 did not disturb that. Maharashtra had two registrars until 16 February 2026 and has four now, because the older of the two was split three ways into ROC Mumbai-I, ROC Mumbai-II at Navi Mumbai and ROC Nagpur. ROC Pune was not part of that split, and MCA still lists a Pune registrar of its own with its own Registrar and contact details.
Treat any page that prints a district list for ROC Pune with suspicion. The instrument that restructured the others names no districts for Pune at all, and MCA publishes no jurisdiction column for any registrar, so a list like that is somebody's arithmetic. ROC Pune is the registrar for Pune and the districts around it. The February 2026 restructuring named districts only for ROC Mumbai-I, ROC Mumbai-II and ROC Nagpur; it left ROC Pune untouched, so a Pune company stays with ROC Pune exactly as before. We confirm the registrar for your specific address before filing.
Everything else is a portal. Company filings are made online on MCA's portal and no office visit is needed. What is local is the reviewing office, the Regional Director who hears an appeal, the state code in the CIN and the Maharashtra registrations that follow. A Maharashtra company's CIN carries the Maharashtra state code, and the code tracks the state rather than the registrar, so nothing about the February 2026 restructuring changes it.
What does LegalX India do differently on an INC-20A file?
We file this form most weeks of the year, which is why its failure points are dull to us and expensive for a founder meeting them once. Our Pune office is at Yashwant Nagar, Near Bharatiya Samajseva, Yerwada, Pune 411006, and the work is handled online with CA and CS support, so come in only if you would rather sit across a table. Where your own registered office sits decides your registrar. Where we sit decides nothing.
The filing is ₹1,499 and takes 3 to 5 days once the papers are complete. More than 15,000 businesses have used LegalX India, and a callback within 30 minutes is how most Pune engagements start. If you want the national picture before the local one, read how INC-20A filing works across India and then come back to the sections above.