When a company borrows against security — hypothecation, mortgage, pledge of assets — the charge must be registered with the ROC in Form CHG-1 within 30 days of creation or modification. When the loan is repaid, the satisfaction is recorded in CHG-4 within 30 days. The two forms share a page because they bracket the life of every secured loan.
The deadlines are asymmetric in a way that surprises borrowers: a charge creation left unfiled past 120 days simply cannot be registered — no condonation exists — while a missed satisfaction can be filed up to 300 days with extra fees and condoned by the Regional Director even beyond. An unregistered charge is void against the liquidator and other creditors, which is why lenders insist on the CHG-2 certificate before disbursing.
CHG-1: what triggers it and the fee ladder
- Creation of a charge on any property or asset, tangible or intangible, in or outside India — and every modification of terms (interest rate, amount, assets covered, ranking).
- Acquiring property already under a charge triggers the same duty.
- Debenture charges use CHG-9, not CHG-1.
- The deadline ladder for charges created on or after 2 November 2018: within 30 days at normal fee; days 31–60 with additional fee; days 61–120 with a further ad-valorem fee (0.025% of the secured amount capped at ₹1 lakh for small companies and OPCs, 0.05% capped at ₹5 lakh for others); beyond 120 days, registration is barred with no condonation.
- If the company does not file within 30 days, the charge-holder (usually the bank) can register it under section 78 after the ROC gives the company 14 days’ notice — and recover the fees from the company.
- The form is signed by both the company and the charge-holder.
CHG-4: recording satisfaction
- Filed within 30 days of full repayment, by the company or the charge-holder, with the charge-holder’s letter or NOC confirming satisfaction attached (mandatory).
- The Registrar can allow the intimation up to 300 days from satisfaction on additional fees; beyond 300 days, condonation lies with the Regional Director under section 87 (CHG-8, the order then filed in INC-28).
- On approval the ROC issues the certificate of satisfaction (CHG-5); the charge disappears from the company’s index — which future lenders check.
Fees
The normal fee for both forms follows the company’s authorised-capital slab — ₹200 to ₹600 — not the loan amount. The charge value matters only for the CHG-1 ad-valorem delay fee between days 61 and 120. Ordinary delay on CHG-4 (within its 300-day window) runs the standard 2x–12x multipliers.
| Authorised share capital | Normal filing fee |
|---|---|
| Less than ₹1,00,000 | ₹200 |
| ₹1,00,000 – ₹4,99,999 | ₹300 |
| ₹5,00,000 – ₹24,99,999 | ₹400 |
| ₹25,00,000 – ₹99,99,999 | ₹500 |
| ₹1,00,00,000 or more | ₹600 |
Penalties beyond fees
- Section 86(1): the company is liable to a penalty of ₹5 lakh and every officer in default ₹50,000 for contraventions of the charge chapter.
- Section 86(2): wilfully furnishing false or incorrect information about a charge — or knowingly suppressing material facts — invites fraud action under section 447, which carries imprisonment.
- The commercial penalty is often the worst: an unregistered charge is void against the liquidator and other creditors under section 77(3), stripping the lender of secured-creditor priority.
How to file on MCA V3
- Log in to MCA V3 → Company e-Filing → Charge Management; pick CHG-1, or CHG-4 with the 8-digit charge ID from the original registration.
- Fill the charge or satisfaction particulars and the charge-holder details.
- Attach the certified charge instrument and sanction letter (CHG-1) or the charge-holder’s satisfaction NOC (CHG-4).
- Affix the DSCs of the company signatory and the charge-holder, with professional certification where required.
- Submit and pay against the SRN; the ROC issues CHG-2 (registration) or CHG-5 (satisfaction).
How this date is calculated (and why other sites say a day earlier)
The Companies Act sets this deadline as a number of days measured from an event — the AGM, the incorporation date, the board meeting. How those days are counted is not left to convention: section 9 of the General Clauses Act, 1897 governs it for every Central Act. Where a period runs from a day, that first day is excluded. Where it runs to a day, the last day is included.
So for a company holding its AGM on the statutory last date of 30 September 2026, the thirty days begin on 1 October, not on 30 September. Day 30 falls on 30 October 2026.
Many commercial compliance sites publish 29 October for the same fact. That comes from counting the AGM day itself as day one — inclusive counting, which section 9 rules out. It is a single day, and a single day is the difference between an on-time filing and ₹100 per day running from the first.
If your AGM is held earlier than 30 September, the deadline moves with it — thirty days from the day after your actual AGM. Our ROC due-date calculator does the arithmetic from your AGM date.
Primary sources
The dates and fees on this page are read off the statute and the MCA’s own published forms, not copied from other guides. You can check every one of them:
- General Clauses Act, 1897 — section 9 (commencement and termination of time)
- Companies Act, 2013 — full text (India Code)
- MCA — company forms and downloads
- MCA — official portal
Verified against the Companies Act, 2013 / LLP Act, 2008, MCA rules and circulars as of 31 July 2026. Your exact position depends on your entity and any notifications or circulars issued since — we confirm it for you, and always recommend checking the official MCA portal. CapEasy is a private consultancy and is not affiliated with any government authority. This page is a guide, not legal advice.