CHG-1 and CHG-9 register the creation or modification of a charge on a company's assets within 30 days of the charge document's date, CHG-4 reports that charge's satisfaction (full repayment) within 30 days of payment, and CHG-8 is the separate application asking the Regional Director to condone a delay or rectify an error once the ordinary window has closed. All four sit inside the same charge-registration family under sections 77-87 of the Companies Act 2013 and the Companies (Registration of Charges) Rules 2014, but each answers a different question: which one you need depends on whether a charge is being created, satisfied, or fixed after the fact.
The one detail that trips up more filings than any other is a cutoff date: 2 November 2018. Charges created or modified on or after that date run on a tight two-tier late-fee ladder that shuts the door for good at 120 days — no CHG-8, no Regional Director, no exceptions. Charges from before that date still get the older, more forgiving 300-day window. Confusing the two regimes is the single most common reason a lender or company discovers, too late, that a charge simply cannot be registered any more.
CHG-1 vs CHG-9 vs CHG-4: which form for which event
Section 77(1) casts the underlying duty: every company creating a charge — within or outside India, on any property, asset or undertaking, tangible or otherwise — must register the charge's particulars with the Registrar, together with the instrument that created or modified it, within 30 days of creation. Rule 3 of the Companies (Registration of Charges) Rules 2014 is the operative rule that names the forms: CHG-1 for charges other than debentures, and CHG-9 for a charge that secures debentures or a debenture trust deed. Section 79 extends the same Section 77 machinery — same forms, same timelines, same fees — to a company acquiring property already subject to a charge, and to any modification of a charge already registered.
CHG-4 sits at the other end of the same charge's life. Section 82(1) requires the company to intimate the Registrar, in Form CHG-4, of full payment or satisfaction of a registered charge within 30 days of that payment or satisfaction — reported under Rule 8 of the same Rules. CHG-1/CHG-9 and CHG-4 are triggered by opposite events on the same 30-day clock: one opens the charge's record, the other closes it.
| Form | What it registers | Legal basis | Normal window |
|---|---|---|---|
| CHG-1 | Creation or modification of a charge (loans, mortgages, hypothecation — anything except debentures) | Sections 77/79 + Rule 3 | 30 days of the charge document |
| CHG-9 | Creation or modification of a charge securing debentures, including a debenture trust deed | Sections 71/77/79 + Rule 3 | 30 days of the charge document |
| CHG-4 | Satisfaction (full repayment/release) of an already-registered charge | Section 82 + Rule 8 | 30 days of payment or satisfaction |
| CHG-8 | Condonation of delay or rectification of an error, decided by the Regional Director | Section 87 + Rule 12 | No fixed window — filed once the ordinary route is closed |
Filing the wrong one — CHG-1 for a debenture-secured charge, or CHG-9 for an ordinary loan — is a routine rejection ground; the underlying instrument decides which form applies, not the lender's preference.
CHG-1 / CHG-9 timelines and late fees — the two regimes around 2 November 2018
Section 77 was substituted by the Companies (Amendment) Act 2019 (assented 31 July 2019) with retrospective effect from 2 November 2018 — so the tighter regime below has applied to every charge created since that date even though the amending Act itself was passed roughly nine months later. That retrospective effective date is the detail most older CHG-1 write-ups get wrong or leave out.
For a charge created or modified on or after 2 November 2018, the window closes in three steps and then shuts for good: normal filing inside 30 days, a straight multiple of the fee for day 31-60, and an ad valorem fee on top for day 61-120. Past day 120, Section 77 gives the Registrar no power to register the charge at all — there is no CHG-8/Regional Director condonation route for this class of delay. If a charge from this period is not filed inside 120 days, it cannot be registered on MCA, full stop.
A charge created or modified before 2 November 2018 is not on this ladder at all. The pre-2019 regime still applies to it: the Registrar may register it if it is filed within 300 days of creation, or within six months of 2 November 2018 (whichever period applies), on payment of the prescribed additional fee — granted by the Registrar directly, without needing Regional Director condonation, and with no ad valorem component. Getting the two regimes crossed is the costliest mistake in this area: a charge dated June 2018 is not subject to the 120-day absolute bar above, but a charge dated December 2018 is, even though both might be discovered unfiled on the same day today.
| When filed (from charge date) | Fee treatment | Route |
|---|---|---|
| Day 0-30 | Normal fee only | Straightforward CHG-1/CHG-9 |
| Day 31-60 | Normal fee + additional fee: 3x for small companies/OPCs, 6x for all others | Still filed directly, no RD involvement |
| Day 61-120 | Additional fee above, plus an ad valorem fee: 0.025% of the amount secured (capped ₹1 lakh) for small companies/OPCs, 0.05% (capped ₹5 lakh) for others | Still filed directly, no RD involvement |
| Beyond day 120 | Not registrable (charges dated on/after 2 Nov 2018 only) | No route exists — CHG-8 does not apply here |
The Companies (Registration of Charges) Amendment Rules 2019 (notified 30 April 2019) put this ad valorem/additional-fee ladder into the fee rules to match the amended Section 77 — it applies only to charges dated on or after 2 November 2018. The exact normal-fee slab by share capital (roughly ₹200 under ₹1 lakh capital, rising to ₹600 at ₹1 crore and above) is widely quoted from the fee rules but this guide could not independently confirm every band against the primary Annexure text — treat the slab as indicative rather than exact until you check the current fee rules for your company's own capital band.
CHG-4: reporting satisfaction, and what the Registrar does next
Once a loan is fully repaid, Section 82(1) requires the company to intimate satisfaction to the Registrar in Form CHG-4 within 30 days of the payment or satisfaction date, per Rule 8. Unlike the creation-side 120-day hard bar, the proviso to Section 82(1) lets the Registrar — on application by the company or the charge-holder — allow the satisfaction filing up to 300 days from the date of payment, on payment of additional fee, without a Regional Director application.
After CHG-4 is filed, Section 82(2) requires the Registrar to notify the charge-holder (the lender) and give it up to 14 days to show cause why the satisfaction should not be recorded — protecting the lender from a company wrongly claiming a loan is repaid. Where the Registrar does enter the satisfaction under Section 82 (or under Section 83, below), Rule 8 requires it to issue a certificate of registration of satisfaction of charge in Form CHG-5 — CHG-5 is never something a company files itself; it is the ROC's own output certificate.
Section 83 gives the Registrar a separate, independent power: on other satisfactory evidence, it can enter a memorandum of satisfaction or release of charged property even without any CHG-4 intimation from the company — and must then inform the affected parties within 30 days of making that entry.
CHG-8: condonation and rectification via the Regional Director
Rule 12 sets the trigger for CHG-8 in the older, pre-2-November-2018-style regime: where a charge instrument is not filed within 300 days of creation or modification, the Registrar cannot register it at all unless the delay is condoned by the Central Government — power delegated to the Regional Director — on an application made in Form CHG-8. Section 87 gives the same Regional Director a second, distinct power under CHG-8: rectifying an omission or misstatement in particulars already registered, including a Section 82/83 satisfaction memorandum.
CHG-8 applications go through a manual, non-STP process on the MCA portal rather than the automatic approval most other forms get; the Regional Director's decision — approval, rejection, or a query — is typically communicated by letter, often via registered email, rather than an instant portal status change. A rectification application (as distinct from a pure delay-condonation one) is generally expected to carry an affidavit and a no-objection confirmation from the charge-holder along with the charge instrument itself.
The one case CHG-8 cannot fix: a creation/modification charge dated on or after 2 November 2018 that has already crossed 120 days. That absolute bar sits in Section 77 itself and Rule 12's condonation route does not reach it.
The Companies (Registration of Charges) Rules 2014 have themselves been amended repeatedly — 2015, July 2018, April 2019, and a Second Amendment on 29 August 2022 that substituted the CHG-4 and CHG-8 e-form templates — so a checklist built against an older CHG-8 layout may no longer match the current form.
The rest of the charge-forms family: CHG-2, CHG-3, CHG-6, CHG-7
- CHG-2 — the Registrar's own certificate of registration of a charge's creation, issued under Rule 6 once CHG-1/CHG-9 (Sections 77/78) is processed. Not filed by the company.
- CHG-3 — the Registrar's certificate of registration of a charge's modification under Section 79, issued the same way as CHG-2 but for modification events.
- CHG-6 — filed by the company in Form CHG-6 within 30 days of a court order (or an instrument's own power) appointing, or the cessation of, a receiver or manager over charged property, under Section 84 and Rule 9. Notice goes to both the company and the Registrar; a second CHG-6 is due on ceasing to hold the appointment.
- CHG-7 — the company's own internal statutory register of all charges, required under Section 85 and Rule 10 to be kept at the registered office in Form CHG-7, updated as charges are created, modified or satisfied, authenticated by a director, company secretary or authorised person, and preserved permanently; the underlying charge instruments themselves must be preserved for 8 years from the date the charge is satisfied.
- Section 78 gives the charge-holder — typically the bank or lender — its own right to step in: if the company fails to register within its Section 77 window, the charge-holder may apply directly (filing CHG-1 or CHG-9 itself), and the Registrar must notify the company and, absent a company filing or sufficient cause, allow registration within 14 days. The charge-holder can then recover any fees or additional fees it paid from the company.
What an unregistered or unpaid-attention charge costs
Section 77(3) is the sharpest consequence: a charge that should have been registered but was not is void against the liquidator and against any other creditor of the company. The underlying debt is not wiped out — the borrower still owes the money — but the lender loses the charge's priority and enforceability the moment a liquidator or competing creditor is in the picture.
Section 86(1) sets the penalty for the company's own default under this chapter of the Act: a penalty of ₹5 lakh on the company and ₹50,000 on every officer in default, with a separate limb providing a fine of not less than ₹1 lakh (extendable to ₹10 lakh) on the company, and for the defaulting officer, imprisonment up to 6 months or a fine of not less than ₹25,000 (extendable to ₹1 lakh), or both. Section 86(2) goes further for deliberate misconduct: anyone who wilfully furnishes false or incorrect charge information, or knowingly suppresses material information required under Section 77, is liable for action under Section 447 — the Companies Act's fraud provision.
Where this shows up in practice
Charge filings typically arise from a handful of ordinary lending events: a term loan secured by a mortgage or hypothecation over fixed assets, a cash-credit or overdraft limit secured by hypothecation of stock and book debts, a vehicle loan hypothecating the vehicle, or a lease/hire-purchase arrangement where the lessor's interest is registered. In every case the 30-day clock in Section 77 runs from the date the charge document itself — the loan, hypothecation or lease deed — is executed, not from the date the loan money is actually disbursed, which is an easy date to mix up under pressure.
Practitioners commonly point to a missing or incomplete charge instrument, or particulars on the webform (amount secured, date of creation, charge-holder details) that do not match the instrument attached, as frequent reasons a CHG-1 or CHG-9 filing bounces back for correction — alongside simply reaching for the wrong form between CHG-1 and CHG-9. For the mechanics of preparing and filing CHG-1 itself — attachments, the e-form fields, and the step-by-step MCA V3 process — see the dedicated CHG-1 guide.
This entire regime governs companies registered under the Companies Act 2013. LLPs register their charges separately, under Form 8 of the LLP Rules filed with the LLP Registrar — an "LLP charge creation form" search should be routed there, not to CHG-1/CHG-9.
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:
- Companies Act 2013, Section 77 (Duty to register charges) — text incl. 2019 amendment provisos
- Companies Act 2013, Section 78 (Application for registration of charge)
- Companies Act 2013, Section 82 (Company to report satisfaction of charge)
- Companies Act 2013, Section 87 (Rectification by Central Government in register of charges)
- Companies (Registration of Charges) Rules 2014, Rule 12 (CHG-8 condonation/rectification)
- CHG-1 fee/timeline table under the Companies (Registration Offices and Fees) Rules 2014
Verified against the Companies Act, 2013 / LLP Act, 2008, MCA rules and circulars as of September 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.