Blog · MCA Compliance
INC-20A Filing: How to File the Commencement of Business Declaration in 180 Days
INC-20A filing is the declaration of commencement of business that a new company with share capital must file with the ROC within 180 days of incorporation. A director declares that every subscriber has paid for their shares. Without it, the company cannot start business or borrow, and faces penalties.
What is INC-20A and who must file it?
INC-20A is the e-form on the MCA portal for the declaration of commencement of business under section 10A of the Companies Act, 2013. In plain terms, it tells the Registrar of Companies (ROC) that the shareholders have paid for their shares and the company is ready to begin work.
The requirement applies to companies with share capital that were incorporated on or after 2 November 2018. A company limited by guarantee without share capital, such as many Section 8 companies, is generally outside this requirement. If you are unsure about your case, confirm before the deadline passes.
How long do you have to file INC-20A?
You have 180 days from the date of incorporation shown on your certificate of incorporation. Count from that date, not from the day your PAN, bank account or first invoice is ready.
Some limited relief was given earlier for companies incorporated in early 2020, but for a new company today the 180-day window is the working rule. Treat the day 150 as your internal deadline so there is room for bank statements and professional verification.
The company must not start business or exercise borrowing powers until INC-20A is filed, so file it before your first sales invoice or loan.
What documents are needed for INC-20A?
The form is signed by a director with a digital signature and certified by a practising Chartered Accountant, Company Secretary or Cost Accountant. Keep the following ready before you begin.
Bank proof of share money
A current account statement showing that subscribers paid for their shares.
Registered office proof
Verification of the registered office, often with photographs, as the ROC may require.
Director’s DSC and DIN
A valid digital signature certificate and the director’s DIN for signing.
Professional certificate
Certification by a practising CA, CS or Cost Accountant before filing.
Incorporation details
CIN, company name and incorporation date from your certificate.
Regulator approval
Only if your business needs a sectoral licence, such as from the RBI.
How to file INC-20A on the MCA portal, step by step
- Confirm the subscribers have paid. Check that every subscriber to the memorandum has paid the share value and that the money shows in the company bank account.
- Collect proof. Gather the bank statement, registered office proof and any regulator approval.
- Prepare the e-form. Log in to the MCA portal, open INC-20A and enter the CIN. Company details fill in automatically.
- Attach documents. Upload the bank proof and other attachments the form asks for.
- Get it certified and signed. A practising professional certifies the form, then a director signs with a DSC.
- Pay the fee and keep the SRN. Pay the fee shown on the portal and save the acknowledgement for your records.
Many founders have the incorporation done by a provider and then miss this step. If you are still at the start, see our guide on how to register a private limited company online, and our private limited company setup service.
What happens if you miss the INC-20A deadline?
As per current rules, the company can be fined up to Rs 50,000, and each officer in default can be fined Rs 1,000 for every day the default continues, up to Rs 1,00,000. The ROC may also start action to remove the company name from the register if it believes the company is not carrying on business.
Late filing also usually carries additional fees on the form. Check the current amount on the MCA portal before you file.
If you file on time
- Company can start business and borrow
- No penalty on the company or directors
- Clean ROC record from day one
- Easier bank and investor due diligence
If you miss the deadline
- Business activity and borrowing are restricted
- Penalty on company and officers
- Risk of ROC strike-off action
- Extra fees and more paperwork later
Common INC-20A mistakes to avoid
Counting the wrong date
The 180 days start from incorporation, not from your first bank deposit.
Share money not paid in
Subscribers must have actually paid. A promise or loan entry is not enough.
Weak office proof
Unclear office evidence can delay certification. Keep it clear and current.
After INC-20A, your regular filings begin. Read our annual MCA compliance checklist and plan your annual MCA compliance so nothing else slips. You can also read the official guidance on the MCA portal.
BizSetups Consulting Private Limited, Gurgaon, a Zoho Authorized Partner, helps new companies with ROC filings and ongoing compliance.
Frequently asked questions
Is INC-20A mandatory for every company?
No. It is required for companies with share capital incorporated on or after 2 November 2018. Companies without share capital are generally not required to file it. Confirm your company type before relying on this.
What is the due date for INC-20A?
The due date is 180 days from the date of incorporation. Count from the date on the certificate of incorporation. Aim to file well before the last day, because bank proof and certification can take time.
What is the penalty for not filing INC-20A?
Yes, there are penalties. As per current rules, the company can be fined up to Rs 50,000 and each officer in default Rs 1,000 per day, up to Rs 1,00,000. Strike-off action is also possible.
Can I start business before filing INC-20A?
No. A company covered by the rule should not start business or use its borrowing powers until the declaration is filed. File first, then begin invoicing or taking loans.
Who certifies and signs INC-20A?
A practising Chartered Accountant, Company Secretary or Cost Accountant certifies the form. A director then signs it with a digital signature certificate. Keep the DSC valid and the DIN handy.
How much does INC-20A filing cost?
The government fee depends on the company’s share capital and is shown on the MCA portal. Professional charges vary, so ask for a written quote. Late filing adds extra fees.
What is the difference between INC-20A and INC-22A?
INC-20A is the declaration of commencement of business. INC-22A, also called SPICe+ active company tagging, is a separate form that verifies the company’s registered office details. Do not confuse the two.
Not sure whether your new company has filed INC-20A, or close to the 180-day limit? Book a free consultation and we will check your status and the next filings.
+91 92788 13303Need help with this for your business?
Talk to a BizSetups expert and get a clear plan, cost and timeline.
Related service: XBRL Conversion & Filing Services | Professional Tax Registration and Return Filing. Talk to our team for a free consultation.