INC-20A: Commencement of Business Declaration Explained
Publishing Date: 7 October, 2026
Getting your certificate of incorporation is only the start. A newly incorporated company with share capital must also tell the Registrar of Companies (RoC) that its shareholders have actually paid for their shares. This is done through Form INC-20A, the declaration for commencement of business, under Section 10A of the Companies Act, 2013.
Who must file INC-20A?
- Private limited companies, public companies and one person companies with share capital
- Incorporated on or after 2 November 2018
Until this declaration is filed, the company should not commence business or exercise borrowing powers.
Due date
The form must be filed within 180 days of incorporation. Plan for it early: you need a bank account, the subscription money credited, and the registered office verified before you can file.
Documents required
- Bank statement or certificate showing receipt of subscription money from each subscriber to the MOA
- Proof of registered office, if not already filed (INC-22)
- DSC of a director
- Certification by a practising CA, CS or CMA
Step-by-step process
- Open a current account in the company's name.
- Each subscriber transfers their share subscription amount to that account.
- Obtain the bank statement reflecting these credits.
- Prepare INC-20A on the MCA V3 portal and attach the evidence.
- Get it signed by a director and certified by a professional, then pay the fee and submit.
Penalty for delay or non-filing
| Who | Penalty |
|---|---|
| Company | Rs 50,000 |
| Every officer in default | Rs 1,000 per day, up to Rs 1,00,000 |
The RoC can also treat a company that has not filed INC-20A as not carrying on business and begin the process of striking off its name.
Common mistakes
- Directors paying subscription money from the company's own funds or in cash
- Amount credited not matching the subscription stated in the MOA
- Waiting until day 179, when the bank statement or DSC is not ready
If you recently incorporated a company, let us handle INC-20A filing along with your first-year auditor appointment.
Why Choose Vaidam Consultancy?
Our team of chartered accountants, company secretaries and legal professionals handles the paperwork so you can focus on growing your business.
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Frequently Asked Questions
Q1. Is INC-20A required for every company?
It is required for companies with share capital incorporated on or after 2 November 2018. Companies without share capital, such as many Section 8 companies, are not covered.
Q2. What is the deadline for INC-20A?
Within 180 days from the date of incorporation.
Q3. Can a company open a bank account before INC-20A?
Yes. In fact the bank account is needed first, because proof of receipt of subscription money is attached to the form.
Q4. What if INC-20A is never filed?
Penalties apply to the company and its officers, and the Registrar may start action to remove the company's name from the register.
Related guides
Mukul Tomar writes Vaidam Consultancy’s guides on company registration, GST, income tax and ROC compliance. An experienced blog writer on Indian tax and business law, his articles have also been published on TaxGuru. He turns complex rules into clear, practical steps that business owners can act on.
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