Form PAS-3 Return of Allotment 2026: DSC Rules, Deadline & Attachments

Form PAS-3 is the return a company files with the Registrar of Companies after allotting shares or other securities. It must be filed within 30 days of the allotment and is signed digitally with a DSC.

What is Form PAS-3 and when is it due?

PAS-3 is the return of allotment under Section 39(4) of the Companies Act, 2013, prescribed in the Companies (Prospectus and Allotment of Securities) Rules, 2014. It is due within 30 days of the date of allotment.

The 30 days run from the allotment date itself, not from the board meeting or the date funds arrived. Each allotment needs its own return, so a company that allots in several tranches files several times. Confirm the current rules on the MCA portal.

When does a company need to file PAS-3?

Whenever it allots shares or other securities, whether through a rights issue, a bonus issue, a preferential allotment or a private placement.

The return tells the Registrar who received the securities, how many, at what price, on what date and under which authority. Startups raising funding rounds and companies increasing paid-up capital are the most common filers.

Does Form PAS-3 need a DSC?

Yes. The form is filed on the MCA portal and signed with a Class 3 DSC registered on the MCA portal by an authorised director. Depending on the form version, certification by a practising professional (CA, CS or cost accountant) may also be required, so check the live form.

Most companies use a director's Class 3 individual DSC; see what MCA21 requires, why Class 2 is no longer issued, and the FIPS 140-3 token rule.

What documents are attached?

The attachments depend on the type of allotment, but a list of allottees and the board resolution are standard.

• List of allottees with their details, number of securities and price.
• Certified copy of the board resolution approving the allotment.
• For private placements and preferential allotments, the special resolution and offer documents.
• A valuation report where the price was set by a registered valuer.

Follow the checklist on the live form, since attachment requirements can change.

How to prepare: checklist

Note the allotment date first, then confirm the signer's DSC is valid and registered before you start.

• Record the allotment date and count 30 days from it.
• Check the signer's DSC expiry — see how to check DSC validity.
• Make sure the DSC is registered on the MCA portal; re-register after a renewal if the certificate changed.
• Fill the form, attach the documents, sign with the DSC and pay the fee shown on the portal.
• Keep the SRN and acknowledgement for your records.

What happens if PAS-3 is filed late?

Late filing attracts additional filing fees that rise with the length of the delay, and Section 39 provides for a penalty on the company and its officers in default.

Amounts can change, so check the MCA portal or your CA or CS for the current position instead of relying on a fixed figure.

Common errors

An expired or unregistered DSC, a token the signing utility cannot detect, or counting the 30 days from the wrong date are the usual problems.

• Expired DSC found at the last step — renew early.
• Token not detected or emSigner not running — see common DSC errors and fixes.
• Counting from the board meeting date instead of the allotment date.

Related MCA guides

See DIR-12 director changes, AOC-4 & MGT-7 filing, DPT-3 return of deposits and ADT-1 auditor appointment.

Frequently Asked Questions

General guidance only. Confirm due dates, fees, penalties and form fields on the MCA portal or with a professional.