What is PAS-6? The half-yearly reconciliation explained

PAS-6 is a reconciliation: the share capital your books say you have issued, matched against what the depositories (NSDL and CDSL) say exists in demat, plus whatever remains in physical form. Twice a year, unlisted companies covered by Rule 9B must file this reconciliation with the ROC within 60 days of each half-year end.

Why does it exist? Because dematerialisation only protects shareholders if someone regularly checks that the demat records and the company’s register agree. A mismatch — shares issued but never credited, or credited but never issued — is exactly the kind of thing that surfaces during a funding round at the worst possible moment.

Who is covered? Every unlisted public company (Rule 9A) and, since October 2023, every private company that is not a "small company" (Rule 9B). Small means paid-up capital of 4 crore rupees or less AND turnover of 40 crore rupees or less, tested at each financial year end. Two traps inside that definition: holding and subsidiary companies are never small regardless of size, and a company that stops being small gets 18 months from that year end before Rule 9B bites.

The practical work is unglamorous: get the RTA/depository confirmations, total the demat holdings per class, add physical holdings, and reconcile against the register of members line by line. Then a practising CS or CA certifies the form. If the numbers do not tie out, you want to know before the form is due — not while it is being signed.