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The Filing Most Founders Miss in Their First Six Months

INC-20A is the declaration a company with share capital files with the MCA within 180 days of incorporation, confirming every subscriber has paid for their shares. Until it is filed the company cannot lawfully commence business or borrow, and missing the deadline costs ₹50,000 on the company plus ₹1,000 a day on each officer in default. Your certificate of incorporation arrived, the bank account is open, you may have started invoicing: the clock started on the day you incorporated.

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INC-20A at a glance (position in October 2026)

PointWhat applies
Form and lawForm INC-20A, the declaration for commencement of business under Section 10A of the Companies Act, 2013 and Rule 23A of the Companies (Incorporation) Rules, 2014
Due dateWithin 180 days of the date of incorporation shown on the certificate of incorporation
Who filesEvery company with share capital incorporated on or after 2 November 2018: private limited, OPC and public companies
Who does notCompanies incorporated before 2 November 2018, companies without share capital, and LLPs
What it declaresThat every subscriber to the memorandum has paid for the shares they agreed to take
Government fee₹200 to ₹600 by nominal share capital, plus an additional fee of 2 to 12 times if late
Penalty for not filing₹50,000 on the company; ₹1,000 a day on each officer in default, up to ₹1,00,000
Other riskPhysical verification of the registered office under Section 12(9) and strike off under Section 248
Our professional feeFrom ₹2,199, excluding GST and the MCA fee, filed in 2 to 3 working days once the bank proof is in order

Worked example: a company incorporated on 15 April 2026 reaches day 180 on 12 October 2026. If its bank statement still does not show each subscriber's money arriving from their own account, that is the first thing to fix, because INC-20A cannot be filed honestly without it.

INC-20A government fee and late fee

The MCA fee is fixed by the company's nominal share capital, the authorised capital in the memorandum, not the paid-up amount.

Nominal share capitalNormal MCA fee
Less than ₹1,00,000₹200
₹1,00,000 to ₹4,99,999₹300
₹5,00,000 to ₹24,99,999₹400
₹25,00,000 to ₹99,99,999₹500
₹1,00,00,000 or more₹600

File after day 180 and the portal adds an additional fee, worked out as a multiple of the normal fee:

Delay after the 180-day due dateAdditional fee
Up to 30 days2 times the normal fee
More than 30 and up to 60 days4 times
More than 60 and up to 90 days6 times
More than 90 and up to 180 days10 times
More than 180 days12 times

Worked example: a company with ₹10,00,000 authorised capital pays a normal fee of ₹400. Filed 42 days late, the additional fee is 4 × ₹400 = ₹1,600, so the MCA challan is ₹2,000. The fee is the small part. The Section 10A penalty of ₹50,000 on the company and up to ₹1,00,000 on each officer in default is adjudicated separately under Section 454.

Sources: Section 10A and Section 12(9), Companies Act, 2013; Rule 23A, Companies (Incorporation) Rules, 2014; Companies (Registration Offices and Fees) Rules, 2014. The MCA21 challan at the time of filing is final.

Five mistakes that get INC-20A returned or questioned

  • One founder pays for everyone. Each subscriber's money must come from their own account and match their shares.
  • Cash deposits. A cash credit does not show who paid; use a bank transfer from the subscriber.
  • Amount does not tie to the memorandum. ₹1,00,000 subscribed means ₹1,00,000 received, split as the shareholding is split.
  • Filing before the money lands. The declaration says the money has been received; the bank statement has to agree.
  • Trading and borrowing before filing. Section 10A bars both until the declaration is on record. A director's loan counts as borrowing.

INC-20A is the first filing in a longer first year. The first auditor appointment is due within 30 days of incorporation, every director needs current director KYC, now on a three-yearly cycle, and the first AOC-4 and MGT-7 come after the first AGM, all covered under annual compliance for private limited companies.

Transparent 3-tier pricing

Pick the speed and depth that matches your need. Same quality, same CA team — only the timeline changes.

starter

₹2,199

Timeline: 2–3 working days

INC-20A drafting and filing
Board resolution
Bank proof review before filing
Professional certification
First-year compliance calendar
ADT-1 auditor appointment
DIR-3 KYC for up to 2 directors
Full first-year annual ROC filing
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standard

₹4,999

Timeline: 3–5 working days

INC-20A drafting and filing
Board resolution
Bank proof review before filing
Professional certification
First-year compliance calendar
ADT-1 auditor appointment
DIR-3 KYC for up to 2 directors
Named dedicated CA and CS

pro

₹12,999

Timeline: Across your first year

Everything in Growth
Full first-year annual ROC filing
AOC-4 and MGT-7 / MGT-7A after the first AGM
DIR-3 KYC for up to 2 directors
First-year compliance calendar, managed
Named dedicated CA and CS

Government fee — paid by you at actuals

The MCA filing fee on INC-20A runs from ₹200 to ₹600 depending on the company's nominal (authorised) share capital, under the Companies (Registration Offices and Fees) Rules, 2014. If you are past the 180-day deadline, an additional fee is charged as a multiple of that normal fee, stepping up from 2 times for a delay of up to 30 days to 12 times beyond 180 days. Both are paid to the government at actuals, over and above our professional fee. Where the form is already late we compute the additional fee as at the filing date and tell you the number before you commit to anything. The penalty under Section 10A is separate from these fees.

Every price above is a professional fee, excluding GST and government charges. 50% upfront, 50% on delivery.

All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

How it works

Step 1

Check the money actually landed

The amount credited must match the subscription in the memorandum and must come from each subscriber's own account. This cannot be backdated, so it gets fixed first if it is missing.

Step 2

Board resolution and drafting

We draft the board resolution authorising the filing and prepare the declaration under Section 10A.

Step 3

Professional certification

The form is certified by a practising professional before it goes on record.

Step 4

File with the bank proof

Filed with MCA against your DSC, with the bank statement evidencing receipt of subscription money from each subscriber attached.

Step 5

Whatever comes next

If the Registrar has already issued an adjudication notice under Section 454, we deal with it. If not, we put the rest of your first-year calendar in place.

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Documents required

Bank statement showing receipt of subscription money from each subscriber
Certificate of incorporation, MOA and AOA
Board resolution authorising the filing
Digital signature of one director
Sectoral regulator approval, if your objects need one

Why CorporateWalla®?

What INC-20A is, in one line

A declaration that the shareholders actually paid for their shares. Under Section 10A of the Companies Act, a company registered with share capital cannot commence business or borrow anything until a director files a declaration confirming that every subscriber to the memorandum has paid the value of the shares they agreed to take. You declared ₹1,00,000 of paid-up capital at incorporation; the government wants to see that ₹1,00,000 land in the company's bank account, from the shareholders, before you trade.

The cost of missing it

₹50,000 on the company. ₹1,000 per day on every officer in default, capped at ₹1,00,000. An additional fee on the form itself of up to 12 times the normal fee, depending on how late it is. The Registrar may also have the registered office physically verified under Section 12(9) where there is reason to believe the company is not carrying on business. And the one nobody mentions — the Registrar may initiate action to strike your company off under Section 248, on the reasonable ground that it is not carrying on business. A company that never filed INC-20A and never filed its annual returns is precisely what a strike-off drive is designed to catch.

What you cannot do until it is filed

Commence any business operations, or exercise any borrowing powers — no loan, no credit line, no director's loan drawn as borrowing. Your bank will open a current account on the certificate of incorporation alone and plenty of founders start trading the same week. That does not make it lawful. It becomes a disclosed non-compliance the first time an investor, a lender or an acquirer reads your file, and the fix is retrospective while the dates do not lie.

The one thing that makes filings fail

Bank proof. The amount credited must match the subscription in the memorandum, and it must come from each subscriber's own account. What does not work: one founder transferring the whole amount for both shareholders, money routed through a third party, a round figure that does not tie to the shareholding split, cash deposits. If your subscription money went in the wrong way, we tell you before we file, not after the form is returned.

Already past 180 days? File now

The officer penalty accrues daily and the additional fee steps up with each delay band, and neither stops until the form is on record. In order: confirm the subscription money is actually in the account, compute the additional fee as at the filing date so you know the number before you commit, file with the bank proof, then deal with any adjudication notice under Section 454 if the Registrar has already issued one.

The MCA amnesty does not help here

CCFS-2026, which closed on 15 September 2026 after two extensions, was aimed at overdue annual filings such as AOC-4, MGT-7/MGT-7A and ADT-1, dormant status and strike off. INC-20A was never part of it and carries its full additional fee.

The rest of your first year

INC-20A is the first of several. Within the first year a new private limited company also needs the first auditor appointed within 30 days of incorporation, ADT-1 filed, director KYC kept current under the three-yearly cycle, AOC-4 and MGT-7 or MGT-7A after the first AGM, and its first ITR-6. Our Growth and Complete plans cover that whole calendar so you are not doing this again in nine months.

Frequently asked questions

180 days from the date of incorporation.

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