Form INC-20A: Due Date, Penalty & Filing Rules | FinTax24

TL;DR

Form INC-20A is a key form for every new firm. You must file it within 180 days of firm setup. It proves each owner put their share cash into the bank. The bank slip shows the cash is in. If you do not file, you face a fine of ₹50,000. You cannot start work without it. You cannot borrow cash.

Quick Answer: What Is Form INC-20A?

Form INC-20A is the official form to start your trade. Every firm set up in India with share cash must file this form. You file it with the ROC on the MCA site.

You set up a Private Limited firm or an OPC. You get a setup slip. That paper gives life to your firm. But the law does not let you start work on day 1.

Under Section 10A of the Companies Act, 2013, you must first open a bank account. Each owner must put their share cash into that account. Then you file Form INC-20A. It shows the cash is in.

Filing this form tells the MCA that you have real funds. It proves your firm is ready to run.

Why Section 10A Stops Work Before You File

The law brought in Section 10A to stop fake shell firms. The rule sets two hard blocks until your form gets approved.

First, you cannot start trade. Your firm cannot bill clients. It cannot sign sales deals. It cannot ship goods. It cannot offer paid help.

Second, you cannot borrow funds. Your firm cannot take a bank loan. It cannot take a credit line. It cannot borrow cash from directors. It cannot borrow from outside folks.

If you sign deals or take loans before you file, those deals can fail in court. Banks can freeze your account. They can drop loan offers if you cannot show your INC-20A paid slip.

Who Must File Form INC-20A

Not every business setup files this form. Here is who must file and who is free from it:

Firm Type	Must File Form INC-20A?	Rule
Private Limited Company	Yes (Must File)	Section 10A of Companies Act, 2013
One Person Company (OPC)	Yes (Must File)	Section 10A of Companies Act, 2013
Public Limited Company	Yes (Must File)	Section 10A of Companies Act, 2013
Section 8 Non-Profit Firm	Yes (Must File)	If set up with share cash
Limited Liability Partnership (LLP)	No (Free)	Governed by LLP Act, 2008
Partnership Firm	No (Free)	Governed by Partnership Act, 1932
Sole Proprietorship	No (Free)	Unregistered small shop

You may run a trade or plant in Gujarat. If it is a Private Limited firm or OPC, this form is a must. If you run an LLP or simple firm, you do not file it.

The 180-Day Cut-Off and Timeline

The clock for Form INC-20A starts on the exact day on your setup slip.

You get 180 days from the day your firm was born. If day 180 falls on a Sunday or holiday, file before that date. That keeps you safe from extra late fees.

Here is a clear step plan for new owners in Gujarat:

• Day 1: You get your setup paper from ROC Ahmedabad or the central unit.
• Day 2 to 30: Open your firm current bank account with your PAN and setup slip.
• Day 31 to 45: Each owner sends their exact share cash from their personal bank account.
• Day 46 to 60: Download the bank sheet. It shows the cash in and the names of the owners.
• Day 61 to 90: Pass a board vote. Fill Form INC-20A. Get professional sign-off.
• Day 91 to 120: Upload the form on the MCA site. Pay the fee. Get your paid slip.

Do not wait for the last week. Opening a firm bank account in Surat, Rajkot, or Ahmedabad can take two to three weeks.

Papers Needed Before You File

Gather these papers before you start to file online:

1. Firm Bank Account Statement: This must show the full cash paid by each owner. Cash paid at the bank desk is not valid. The credit lines must match the MOA share terms.
2. Bank Proof Slip: A bank letter or stamped credit slip that proves the cash came from each owner.
3. Board Vote Paper: A written board vote that okays the form to start business.
4. Regulator Approval If Needed: Your trade may need an RBI nod, SEBI nod, or food license. If so, attach that paper too.
5. Office Photos: A photo of the office front with the firm name board in English and Gujarati. Also add a photo of a director inside the room.

Steps to File on the MCA Portal

Follow these seven steps to file your form:

Step 1: Open Your Bank Account and Put In Cash

Take your setup paper, MOA, AOA, and PAN to the bank. Open a current account. Each owner must transfer their exact share cash by bank transfer or cheque.

Step 2: Get Your Bank Sheet

Once the funds clear, get an official bank sheet. It must show the account number, firm name, date, owner name, and cash amount.

Step 3: Log In to MCA V3

Go to the MCA portal. Log in with your business user ID. Find the form under company e-filing forms.

Step 4: Enter Your CIN

Type your CIN and hit pre-fill. The site loads your firm name, office place, and capital base.

Step 5: Check Boxes and Add Proofs

Tick the box to declare that all share cash has been paid in full. Attach your bank sheet, board vote, and office photos as PDF files.

Step 6: Add Digital Signatures

A director must sign the form with a Class-3 digital key. A practicing tax professional or company secretary must check and sign it too.

Step 7: Pay the Fee and Save the Slip

Pay the small government fee online. The portal gives you a service code and a paid slip. Keep this slip in your firm files.

Government Fees and Late Fines

The base MCA fee depends on your firm share capital:

Share Capital	Normal Government Fee
Under ₹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

Late Fee Scale Beyond 180 Days

If you file after 180 days, you must pay extra late fees:

Days Late	Extra Fee Scale
Up to 30 days late	2 times the base fee
31 to 60 days late	4 times the base fee
61 to 90 days late	6 times the base fee
91 to 180 days late	10 times the base fee
Over 180 days late	18 times the base fee

Heavy Fines Under Section 10A

The extra fee is just for filing late. The law also puts heavy fines on default:

• Fine on the Firm: A fixed fine of ₹50,000.
• Fine on Each Director: ₹1,00,000 top fine. It runs at ₹1,000 per day for each day of default.

What Happens If You Do Not File

If you miss Form INC-20A, you face three large risks:

1. ROC Strike-Off Notice: You miss the 180-day cut-off. Under Section 10A(3), the ROC can close your firm. The officer can strike off your name from the registry.
2. Director KYC Block: Your firm gets flagged on the portal. This can block annual filings and your DIR-3 KYC Filing.
3. Cannot Take Loans or Sell Shares: Banks and investors ask for the INC-20A paid slip. You cannot sell shares or take fresh funds until this form is on file.

Real Case: Rajkot Firm Saves Bank Credit

In 2025, a brass parts maker in Rajkot set up a Private Limited firm. The team was busy with plant work, tools, and GST registration.

By month five, on day 155, the firm asked for a ₹25 lakh cash credit limit from a bank in Rajkot. The bank officer checked MCA files. The firm had not filed Form INC-20A. The bank put the loan on hold.

The founders called FinTax24. Our team verified that the two owners had sent ₹1,00,000 of share cash to the bank. We drafted the board vote. We got the practicing sign-off. We filed the form on day 168.

The MCA approved it in 48 hours. The bank then released the loan line with zero late fine.

Five Common Mistakes to Avoid

1. Paying Share Cash Over the Counter: You cannot deposit paper cash at the bank desk. The cash must come by bank transfer or cheque from the owner’s personal bank account.
2. Paying from a Kin Account: The money must come from the exact person named in the MOA. Cash from a spouse or father does not count.
3. Counting 180 Days from Bank Date: The 180-day clock starts on the date on your setup slip. It does not start on the date your bank account opened.
4. Missing OPC Firms: Solo owners often think OPCs do not need this form. The rule applies to every firm with share cash. It covers OPCs too.
5. Skipping Office Board Photos: If your office has no name board or no photo, the sign-off will stop.

Frequently Asked Questions

Is Form INC-20A a must for all new firms?

Yes. Every firm set up after 2 November 2018 with share cash must file Form INC-20A within 180 days.

Can I file without a firm bank account?

No. You must open a firm bank account first. Each owner must deposit their share cash into that account.

Can share cash be paid in paper money?

No. Cash paid at the bank desk is not valid. The money must move by bank transfer or cheque.

What is the fine for filing late?

You pay up to 18 times the base fee to MCA. In addition, the firm can face a fine of ₹50,000, and each director can face up to ₹1,00,000.

Can my firm borrow funds before filing?

No. Section 10A clearly bars all loans and commercial work until the form is filed and approved.

Who must sign Form INC-20A?

A director must sign with a digital key. A practicing tax professional or company secretary must check and sign it too.

Does an LLP file Form INC-20A?

No. LLPs fall under the LLP Act, 2008. They file Form 3 and do not file Form INC-20A.

Can ROC close my firm if I do not file?

Yes. Under Section 10A(3), the ROC can issue a notice and strike off your firm name from the registry.

Primary Sources & Legal Rules

• Section 10A of the Companies Act, 2013 (Commencement of business)
• Rule 23A of the Companies (Incorporation) Rules, 2014
• Section 403 of the Companies Act, 2013 (Fee for filing)
• Ministry of Corporate Affairs portal: mca.gov.in
• MCA Notification S.O. 5621(E) dated 18 December 2018

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Need help setting up your firm or filing your ROC forms? See our Private Limited Company Registration and MCA & ROC Compliance services. For ongoing rules, read our Annual ROC Filing Guide and Company Registration Guide.

Disclaimer: This article gives plain facts on legal rules at publication time. Rules can change with new government notices. Take professional help for your exact firm needs.