Event-Based MCA Filings — ADT-1, CHG-1, PAS-3: Documents and Evidence
Most delay on Event-Based MCA Filings — ADT-1, CHG-1, PAS-3 comes down to paperwork that was not ready, so it is worth knowing what will be asked for. 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.
A director resigned six months ago but MCA still shows them as a director. What went wrong?
Two separate filings are needed when a director resigns: DIR-12 filed by the company (within 30 days of the Board's knowledge of the resignation) and DIR-11 filed independently by the resigning director themselves. If the company files DIR-12 but the individual never files their own DIR-11, or if neither is filed, MCA's public record continues to show the person as an active director — which can affect their DIN status on other engagements and their apparent liability exposure for the company's ongoing defaults. PNPC advises both the company and, where engaged, the individual director on completing both filings.
In practice: We always advise a resigning director to also file their own DIR-11 rather than relying solely on the company. It is a small extra step that protects the individual's own record independently of what the company subsequently does.
Does PNPC handle event-based filings for companies with foreign directors or NRI shareholders?
Yes. Foreign directors and NRI shareholders trigger the same MCA event-based obligations as any other director or shareholder change, plus additional layers: DIN and DSC procurement for a new foreign director involves apostille and notarisation of identity documents; share allotment to a non-resident triggers FC-GPR reporting to RBI through the Single Master Form on the FIRMS portal (within 30 days of allotment) in addition to PAS-3 with MCA; and a foreign director's resignation or removal follows the same DIR-12/DIR-11 process but with cross-border document coordination. PNPC's Dubai office coordinates directly with UAE-resident directors and shareholders so document apostille, DSC video verification, and filing timelines are managed without the individual needing to travel.
In practice: For clients with both an Indian company and a UAE entity, we track event-based obligations on both sides under one calendar — a director change or capital event on one side often has a mirror implication on the other that is easy to miss if the two entities are advised by separate, uncoordinated firms.
What documents does PNPC need from us to file a director change?
For an appointment: the incoming director's DIN (or PAN and identity documents if a fresh DIN application is needed), their written consent to act as director (Form DIR-2), a declaration of non-disqualification (Form DIR-8), and the Board or shareholder resolution approving the appointment. For a resignation: the outgoing director's resignation letter, evidence the Board has acknowledged it, and — separately — the director's own DIR-11 filing. For removal: the Section 169 notice and evidence the director was given an opportunity to be heard before the resolution was passed.
In practice: A common delay is a missing or incomplete DIR-8 declaration — directors sometimes assume a verbal confirmation of no disqualification is sufficient. It is not; the declaration must be a signed document in the prescribed format.
What is the consequence of an incorrect (rather than late) event-based filing?
An incorrect filing — wrong allotment date, wrong charge amount, wrong director details — can be as problematic as a late one, sometimes more so, because it creates an inaccurate public record that a third party may rely on. Correcting it typically requires a rectification filing (where the specific form supports one) or, in some cases, an application to the Regional Director or NCLT for rectification of the register, which is a materially more involved process than a straightforward late filing. PNPC's practice of reviewing the underlying resolution before filing exists specifically to prevent this category of error, which is harder and more expensive to fix after the fact than a delay is.
In practice: Rectification applications may be needed where incorrect charge amounts or allotment details were self-filed through a portal that did not review the underlying transaction documents before submission. It is a meaningfully more expensive and slower fix than getting the original filing right.
How quickly can PNPC onboard our company and take over event-based filing responsibility?
For a company with a reasonably current MCA record and no significant backlog, PNPC can complete onboarding — reviewing the existing Register of Directors and Members, DIN/DSC status of all directors, and any pending or recent events — after which we assume standing responsibility for tracking and filing new triggers as they arise. The onboarding time depends on the case and is confirmed at scoping. For a company with a compliance backlog, onboarding includes the diagnostic and reconstruction phase described elsewhere, which takes longer depending on the number of years and events involved.
In practice: We ask every new client for read access to their MCA master data and recent bank statements as the very first onboarding step — it is the fastest way for us to independently verify the current state rather than relying solely on the client's own recollection of what has and has not been filed.
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.