If your company holds its shares in dematerialised form, the next company-law date on your calendar is not a tax payment at all. The PAS-6 due date for the half-year ended 30 September 2026 is 29 November 2026 — the half-yearly e-form in which a company reconciles its issued share capital against what actually sits in demat and physical form. It falls on a Sunday this half-year, so treat 29 November as the outer edge and file before it; the form asks nothing of your bank account, which is exactly why it slips past teams who track only the deadlines that cost money.
What the PAS-6 due date for the half-year ended 30 September 2026 actually covers
PAS-6 is the Reconciliation of Share Capital Audit Report. It is a half-yearly return, filed with the Registrar of Companies within sixty days from the conclusion of each half-year. The financial year splits into two windows for this purpose — April to September, and October to March — so the half-year that closed on 30 September 2026 reports by 29 November 2026, and the current half-year (October 2026 to March 2027) will report by 30 May 2027. The sixty-day rule is what fixes the date; the half-year end is what starts the clock.
| Half-year period | PAS-6 due date |
|---|---|
| 1 April 2026 – 30 September 2026 | 29 November 2026 |
| 1 October 2026 – 31 March 2027 | 30 May 2027 |
Each PAS-6 is certified by a practising Company Secretary or Chartered Accountant before it is filed. The form is required once your company has an ISIN — the identifier a security gets when it is admitted to demat — even in a half-year where not a single share was actually dematerialised. In other words, obtaining the ISIN is the trigger, not the volume of demat activity, so a company that set up demat and then saw no movement still files a nil-movement reconciliation.
Who has to file — and the private companies newly caught
For years this was an unlisted-public-company obligation under the share-capital-reconciliation rule, and that has not changed: an unlisted public company with share capital files PAS-6 once it holds an ISIN. What has changed is the reach into private companies. Following the 2023 amendment that extended compulsory dematerialisation to private companies that are not small companies, those companies are being pulled into the same half-yearly reconciliation once they obtain an ISIN. Small companies, government companies, Nidhi companies and wholly owned subsidiaries sit outside the requirement. If your company is a private limited that recently went through the demat exercise — opening an ISIN, appointing a registrar and transfer agent, asking shareholders to dematerialise — this is the filing that now recurs every six months, and 29 November 2026 may be one of your first. The precise boundary of the private-company net is worth confirming for your own company before you file, because it is defined by rule rather than by a single turnover line.
What the reconciliation actually checks
The value of PAS-6 is not the filing; it is the exercise the filing forces. You set three numbers beside each other — the share capital on your own register, the holdings recorded as dematerialised at the depositories through your registrar and transfer agent, and any shares still held in physical form — and you make them tie. In a company where share movements are rare, they usually do. In a company that has issued shares, bought some back, transferred holdings between promoters, or changed its RTA in the period, they often do not, and the half-yearly discipline is what catches a difference while it is small.
A gap between your register and the depositories’ records is rarely a rounding error. It is usually an allotment that was never credited, a transfer recorded on one side only, or an ISIN detail that does not match — the kind of thing that is a ten-minute fix this quarter and a due-diligence problem the year you try to raise money or sell.
The cost of treating it as paperwork
Because PAS-6 carries no tax, the instinct is to park it. Two reasons not to. First, it is a continuing obligation: a half-year missed does not disappear, it sits as a default that the next filing does not cure, and the company and its officers carry additional fees that grow with the delay. Second, the reconciliation is a control. A company that files PAS-6 honestly every six months always knows its own capitalisation table is accurate and matches the depositories; a company that skips it discovers the mismatch at the worst possible moment — in an investor’s data room, a bank’s security-creation check, or a buyer’s legal review. The filing is cheap; the surprise is not.
What to do before 29 November
Three steps clear it. Pull the capital position from your register and your RTA’s benefit-position statement for 30 September 2026 and reconcile them line by line. Resolve any difference at source — correct the register, complete a pending transfer, or raise the discrepancy with the RTA or depository — rather than papering it into the form. Then have the reconciliation certified and filed before the date. If demat is new to your company, build the half-yearly reconciliation into your secretarial calendar now, because the next one (for October 2026 to March 2027) is already running and falls due 30 May 2027. Clean company-law provenance here, untouched by the income-tax changes in force this year — this is a Companies Act obligation and the date is fixed by the sixty-day rule, not by any notification you need to wait for.