Event-Based MCA Filings — ADT-1, CHG-1, PAS-3: After Approval: What Continues
Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 does not end at approval — a set of obligations continues afterwards. The questions below are the ones raised most often in practice; the full scope of the service is on the Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 page.
Can PNPC take over event-based filing for a company that already has an in-house accounts team?
Yes, and this is a common engagement pattern. Many companies have an in-house accounts or finance team capable of bookkeeping and day-to-day operations but without dedicated company-secretarial expertise to track event-based MCA triggers. PNPC can run purely as the event-based compliance layer — reviewing every Board resolution before it is finalised, tracking the resulting filing deadlines, and handling the MCA submissions — while the in-house team continues to manage accounting. We coordinate directly with the finance team rather than duplicating their work.
In practice: The most effective version of this arrangement is one where we are looped in before a resolution is signed, not after. Reviewing a resolution in draft lets us flag missing details (charge amount, allotment price, effective dates) that are expensive to correct once already passed and filed.
How does PNPC price event-based filing services — per filing, or as part of a retainer?
Most PNPC clients engage event-based filing as part of a broader compliance retainer that also covers annual filings, GST, and TDS — this gives us visibility into the full picture of the company's activity and reduces the chance that an event is missed because it fell outside a narrowly scoped engagement. For companies that prefer a standalone arrangement, we also quote per-filing fees for specific one-off events (a single director change, a single charge registration). The exact structure and fee are confirmed in writing before any engagement begins.
In practice: We generally recommend the retainer model over per-filing pricing for active companies — a startup raising funds, hiring, and taking on debt in the same year will trigger several event-based filings, and the retainer removes any incentive (on either side) to under-report events to save a per-filing fee.
Can event-based filing defaults lead to director disqualification, like missed annual filings can?
Director disqualification under Section 164(2) is specifically tied to three consecutive years of default in filing annual returns (MGT-7) or financial statements (AOC-4) — not, on its own text, to event-based filings like ADT-1 or DIR-12. However, event-based defaults compound risk in other ways: an unregistered charge can be void against creditors on winding-up; an unfiled PAS-3 can leave a share allotment on uncertain footing; and a pattern of persistent event-based non-compliance is itself a red flag that regulators, banks, and investors treat as a proxy for weak governance, even where it does not trigger disqualification directly.
In practice: We do not want to overstate the disqualification risk for event-based forms specifically — that consequence is reserved for the annual filing defaults. But we equally do not want to understate the real commercial risk: a messy event-based filing history is one of the first things a sophisticated investor's legal counsel flags in due diligence, and it takes real time to clean up under deal pressure.
Does PNPC also handle LLP event-based filings, or only companies?
LLPs follow a parallel but distinct event-based filing regime under the LLP Act 2008 and LLP Rules — Form 4 for changes in partners or designated partners, Form 3 for changes to the LLP Agreement, Form 8 and Form 11 for the LLP's own annual filings. These are governed by different sections and forms than the Companies Act filings covered in this service, though the underlying discipline — track the trigger, file within the window — is the same. PNPC handles LLP compliance as a related but separately scoped service; ask us to confirm which regime applies to your entity type.
In practice: We occasionally see a company that converted from an LLP still using LLP terminology and deadlines out of habit — a fast way to miss a Companies Act deadline that runs on a different clock than the LLP forms the team is used to.
How does PNPC ensure nothing is missed when our team forgets to mention an event happened?
No compliance process can catch an event nobody discloses, which is why PNPC's engagement structure is built around two complementary safeguards rather than relying on disclosure alone. First, we conduct periodic reviews of bank statements and the Register of Members/Directors as part of the annual audit and compliance cycle, which surfaces most undisclosed events (new loans, share transfers, address changes) even without being told directly. Second, we set an explicit expectation at the start of every engagement: material actions — borrowing, hiring senior staff with equity, changing the board, moving offices — should be flagged to us before they happen, and we repeat this reminder at each periodic check-in rather than assuming it was understood once.
In practice: The bank statement review is, in practice, our most reliable catch-all. An unexplained credit that turns out to be a director's personal loan to the company, or an unexplained payment to a new charge-holder, surfaces reliably there even when nobody remembered to mention it.
Why should we choose PNPC over a company secretary (CS) firm that only does MCA filings?
A standalone CS firm can competently file forms once instructed, but event-based compliance fails most often at the recognition stage — knowing that an event has occurred and requires a filing — not at the mechanical filing stage. PNPC, as a practising CA firm handling audit, tax, and accounting for the same client, sees the bank statements, the loan agreements, the share allotment consideration, and the Board minutes as a natural part of other engagements — which means we are structurally positioned to catch triggers a filing-only CS firm, working from instructions alone, would only learn about if specifically told. We also draft the underlying resolutions and coordinate the accounting and tax consequences (TDS on director remuneration changes, FEMA on foreign allotments) alongside the filing itself.
In practice: This is not a criticism of CS firms generally — many are excellent at what they are instructed to do. The distinction is about visibility: a CA firm already inside your books sees the trigger events as they happen; a filing-only engagement depends entirely on being told.
Where this sits in the wider engagement
Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 rarely arrives on its own. The statutory basis and the current requirements are set out on the Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 service page, and the related services are grouped under Corporate Law.
What PNPC does
PNPC Global has practised since 1986 across India and the UAE. On Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 we take the work end to end — reviewing the facts, preparing and filing what is required, and dealing with the authority through to closure.