Form INC-20A is the declaration of commencement of business under section 10A. Every company incorporated on or after 2 November 2018 with share capital must file it within 180 days of incorporation — and until it is filed, the company legally cannot commence business or exercise borrowing powers.
The core attachment is the company bank statement showing every subscriber has deposited their full MOA subscription money. Miss the window and the price is steep: ₹50,000 on the company, ₹1,000 per day on officers (capped at ₹1 lakh), and the ROC gains the power to strike the company off. CapEasy handles INC-20A as part of post-incorporation compliance.
Who must file INC-20A
- Companies incorporated on or after 2 November 2018 that have share capital — private limited, public and OPC alike.
- Companies without share capital, and companies incorporated before that date, do not file.
- Where the company’s objects need a sectoral regulator (RBI for NBFCs, SEBI, IRDAI), the regulator’s registration or approval must be attached too.
Documents required
- Company bank statement showing each subscriber’s credit of the full amount subscribed in the MOA — from incorporation to the declaration date.
- Sectoral regulator certificate or approval, where applicable.
- The form is signed by a director and must be certified by a practising CA, CS or cost accountant.
Deadline and what late filing costs
The deadline is 180 days from the date of incorporation. Filing later is still possible with additional fees on the standard ladder — provided the ROC has not already begun strike-off action.
| Delay | Additional fee |
|---|---|
| Up to 30 days | 2x the normal fee |
| 31 – 60 days | 4x |
| 61 – 90 days | 6x |
| 91 – 180 days | 10x |
| Beyond 180 days | 12x (no upper band — it stays 12x indefinitely) |
Normal fee is the ₹200–₹600 authorised-capital slab; the multipliers above apply to it.
Penalty and strike-off risk
- Company: ₹50,000 penalty for default.
- Every officer in default: ₹1,000 per day, capped at ₹1,00,000.
- If the 180 days pass and the ROC has reasonable cause to believe the company is not carrying on business, it can initiate removal of the name under section 248(1).
- Until INC-20A is approved, the company cannot start business or borrow — investor money and loans have to wait.
How to file INC-20A on MCA V3
- Confirm every subscriber has remitted their full subscription money to the company account; download the bank statement.
- Obtain the sectoral regulator approval if the objects require one.
- Log in to MCA V3 → Company e-Filing → INC-20A, enter the CIN and confirm receipt details.
- Attach the bank statement (and regulator certificate if applicable).
- Director affixes DSC; a practising CA/CS/CMA certifies with their DSC and membership number.
- Submit and pay against the SRN. Business can commence once the form is approved.
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.