Extension of Timeline for Filing Forms Relating to Significant Beneficial Ownership

The Ministry of Corporate Affairs (‘MCA’) had, by way of its notification dated June 13, 2018, introduced the Companies (Significant Beneficial Owners) Rules, 2018 (‘Rules’) with the intention of identification of significant beneficial owners (‘SBO’) of companies. The Rules mandated, inter alia, certain compliance requirements including filing of Form No. BEN-1 (to be filed by the SBO with the company) and Form No. BEN-2 (to be filed by the company with the relevant Registrar of Companies), each in respect of Section 90 of the Companies Act, 2013.

By way of a Circular dated September 6, 2018, the MCA had extended the timeline for the filing of Form No. BEN-2 (the timeline was extended to 30 days from the date of deployment of Form No. BEN-2 on the MCA-21 portal). The MCA has now, by way of a Circular dated September 10, 2018, stated that in light of representations received from various stakeholders, it will be revising Form No. BEN-1 as well as the due date for filing the form (which was initially September 10, 2018). The revised form as well as the revised due date for filing the same will be notified shortly.

Date:September 2018