You are correct. Form PAS-6 is generally not applicable to listed companies in India.
Here's why:
Therefore, if a company is listed on a stock exchange in India, it will follow the SEBI regulations for share capital reconciliation and will not be required to file Form PAS-6.
Here's why:
- Purpose of PAS-6: Form PAS-6, also known as the "Reconciliation of Share Capital Audit Report," is a half-yearly filing primarily intended for unlisted public companies and, more recently, for non-small private companies in India. Its main objective is to reconcile the company's issued share capital with the shares held in dematerialized (Demat) form with depositories (NSDL and CDSL), as well as shares held in physical form. This helps ensure transparency and accuracy in shareholding records.
- Listed Company Compliance: Listed companies have different, often more stringent, compliance requirements regarding their share capital reconciliation. They are typically governed by the Securities and Exchange Board of India (SEBI) regulations (e.g., SEBI (Depositories and Participants) Regulations, 2018), which mandate a similar reconciliation process but on a quarterly basis and directly with the stock exchanges. Form PAS-6 is essentially the unlisted company's equivalent of this requirement.
Therefore, if a company is listed on a stock exchange in India, it will follow the SEBI regulations for share capital reconciliation and will not be required to file Form PAS-6.