File INC-20A Online | Business Commencement Declaration – LegalDev

Filing INC-20A

  • Compliance
  • Filing INC-20A

File INC-20A – Commencement of Business Declaration

Every company registered in India with share capital must file Form INC-20A before it can legally start operating, open contracts, or draw on its borrowing powers. Miss the 180-day window and the cost isn't just a late fee — it's a statutory penalty on the company and every officer in default. LegalDev prepares and files your INC-20A end to end, so your company can start business the moment its paperwork is right.

File INC-20A – Commencement of Business Declaration

What Is Form INC-20A?

Form INC-20A is a one-time declaration filed under Section 10A of the Companies Act, 2013, confirming that all subscribers to the Memorandum of Association have paid up their agreed share capital. It applies to every company incorporated on or after 2 November 2018 that has share capital — private limited companies, public limited companies, and One Person Companies alike. Section 8 companies (non-profits) are exempt.

Until this form is approved, a company cannot:

  • Commence any business activity
  • Enter into contracts
  • Exercise its borrowing powers
  • Open a current bank account in most cases, or file several other MCA forms

Who Needs to File INC-20A?

  • Private Limited Companies
  • Public Limited Companies
  • One Person Companies (OPC)
  • Any company with share capital incorporated on or after 2 November 2018

Not required for: Section 8 companies and companies without share capital.

INC-20A Filing Deadline

The declaration must be filed within 180 days from the date of incorporation mentioned on the Certificate of Incorporation — not from the date you received the certificate. For example, a company incorporated on 1 January must file INC-20A by 30 June the same year. There is no automatic extension, and ROC grants exceptions only in rare, genuinely exceptional cases.

Documents Required for Filing INC-20A

  • Certificate of Incorporation
  • Memorandum of Association (MOA) and Articles of Association (AOA)
  • Bank statement of the company showing receipt of subscription money from all shareholders
  • Board Resolution authorising the issue of shares
  • Board Resolution authorising the director to sign and file the form
  • PAN card of the company
  • PAN card and address proof of all subscribers
  • Regulatory approval or NOC, if the company's business requires a specific licence (e.g., RBI, SEBI, IRDAI)

INC-20A Filing Process — How LegalDev Helps

  1. Document Collection. We collect your incorporation certificate, MOA/AOA, and bank details.
  2. Subscription Verification. Our team confirms that every subscriber has deposited their full share capital in the company's bank account.
  3. Form Preparation. We draft the declaration and attach the board resolution and bank proof.
  4. Professional Certification. A practising CA, CS, or Cost Accountant certifies the form with their digital signature, as required by MCA.
  5. MCA Filing. We file Form INC-20A on the MCA portal against your company's SRN.
  6. Approval Tracking. We track the SRN status and share the approval confirmation with you.
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Government Fee for INC-20A

The normal MCA filing fee for INC-20A ranges from ₹200 to ₹600, depending on the company's authorised share capital. This is separate from any late-filing multiplier or statutory penalty described below.

Penalty for Late or Non-Filing of INC-20A

Missing the 180-day deadline triggers two separate consequences:

1. MCA Late Filing Fee

The additional government fee rises on a sliding scale — up to 12 times the normal filing fee — the longer the delay continues.

2. Statutory Penalty under Section 10A(2)

  • ₹50,000 penalty on the company
  • ₹1,000 per day of default on every officer in default, subject to a maximum of ₹1,00,000 per officer

Recent MCA adjudication orders show this is actively enforced — companies have been penalised the full ₹50,000 plus six-figure amounts on individual directors for delays running into several months. Directors are required to pay their share of the penalty from personal funds, not company funds.

3. Risk of Strike-Off

If a company neither commences business nor files INC-20A within one year of incorporation, the Registrar of Companies (ROC) can initiate proceedings under Section 248(1)(c) to strike the company's name off the register. Reviving a struck-off company requires an application to the NCLT, which is both time-consuming and costly.

Note: MCA occasionally announces one-time relief schemes (such as past fee-waiver initiatives) for pending filings, but these are exceptions, not the norm. Filing on time remains the only reliable way to avoid penalties.

Consequences of Not Filing INC-20A

  • Company cannot legally start business operations
  • Cannot enter into binding contracts
  • Cannot exercise borrowing powers
  • Marked as "ACTIVE non-compliant" on the MCA portal
  • Directors face personal financial penalties
  • Risk of the company being struck off by the ROC

Why File INC-20A Through LegalDev?

  • Accuracy first — every subscription and bank entry is verified before filing, so your form isn't rejected or flagged for resubmission.
  • CA/CS-certified filing — your form is certified by a qualified professional, as MCA mandates.
  • Pan-India online service — no office visits required; everything is handled remotely and securely.
  • Deadline tracking — we flag your 180-day window in advance so you never file late.
  • Transparent process — you get updates at every stage, from document collection to SRN approval.
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Frequently Asked Questions

Form INC-20A is a declaration of commencement of business under Section 10A of the Companies Act, 2013. All companies with share capital incorporated on or after 2 November 2018 must file it within 180 days of incorporation, except Section 8 companies.

Yes. Filing is mandatory regardless of whether operations have begun. It's the declaration itself — not the business activity — that the law requires within the deadline.

The Certificate of Incorporation, MOA and AOA, a bank statement showing subscription money received, board resolutions, and PAN details of the company and subscribers.

Yes, it is filed entirely online through the MCA V3 portal against the company's CIN and SRN.

Beyond the sliding-scale late fee (up to 12x the normal fee), Section 10A(2) imposes a separate ₹50,000 penalty on the company and ₹1,000 per day on each officer in default, capped at ₹1,00,000 per officer.

Yes, but it will be filed as a delayed filing with additional government fees and will attract the statutory penalty above. The company remains marked "ACTIVE non-compliant" until the form is approved and penalties are cleared.

Beyond financial penalties, the ROC can initiate strike-off proceedings against the company under Section 248(1)(c) if business hasn't commenced or INC-20A hasn't been filed within a year of incorporation.

A practising Chartered Accountant, Company Secretary, or Cost Accountant must digitally certify the form before it is filed with the MCA.

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