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MCA Revised Mandatory Disclosures Form INC-22A

E-Form-INC-22A

MCA Revised Mandatory Disclosures Form INC-22A

Key Amendment – Substitution of Form INC-22A – MCA Notifies Companies (Incorporation) Amendment Rules, 2025

Summary of the latest development regarding the Companies (Incorporation) Amendment Rules, 2025, as notified by the Ministry of Corporate Affairs (MCA). The amendment introduces a revised e-form INC-22A,

Form No. INC-22A (ACTIVE) – Active Company Tagging Identities and Verification. This update is part of The Ministry of Corporate Affairs V3 portal transition and aims to strengthen compliance enforcement and corporate transparency.

Checklist for Filing INC-22A (Revised)

Item Status
Registered Office Photo (External & Internal) ✅
Geolocation (Lat/Long) ✅
Auditor & KMP Details Verified ✅
AOC-4 & MGT-7 SRNs (FY 2017–18) Ready ✅
DINs of All Directors Active ✅
DSCs of Director & CA/CS/CMA ✅

Requirement Documents for DSC 

  • Aadhar Card
  • Pan Card
  • Mobile No.
  • Email I’d

Mandatory Disclosures in the Revised Form INC-22A (ACTIVE) :

Form No. INC-22A (ACTIVE) – Active Company Tagging Identities and Verification. This update is part of MCA’s V3 portal transition and aims to strengthen compliance enforcement and corporate transparency. The substituted form requires comprehensive entity-level information across the following domains:

  1. Company Information
    • Corporate Identity Number (CIN)
    • Name, registered address, email ID
    • Whether the company is listed (Yes/No)
  1. Director Details
    • DIN of all directors
    • Director status (active/disqualified)
    • Digital signature of at least one director
  1. Auditor Information
    • Statutory Auditor(s): Name, PAN, membership number, period of appointment
    • Cost Auditor(s) (if applicable): Similar details as statutory auditor
  1. Key Managerial Personnel (KMP)
    • Managing Director/CEO/Manager/Whole-Time Director: Name and DIN
    • Company Secretary (if appointed): Name and Membership No.
    • Chief Financial Officer (CFO): Name and PAN
  1. Registered Office Verification
    • Photograph showing external and internal views of the registered office, clearly displaying includes Company’s nameplate, & Registered office address
    • Geolocation Coordinates (Latitude & Longitude) of the registered office
  1. Filing Status of Past Returns
  • Mandatory disclosure of filing status and SRNs for:
    • Form AOC-4 / AOC-4 XBRL
    • Form MGT-7
    • Specifically, for Financial Year 2017–18

ROC document / Form Authentication Requirements Digital Signature Certificates (DSC) of A Director (with active DIN) or/ and A Practicing Professional (CA/CS/CMA)

Non-filing of AOC-4 or MGT-7 for FY 2017-18 may render the form defective or the company inactive under MCA records.

Implications & Possible Consequences for Non-Compliant Companies

  • Non-filing of Form INC-22A may lead to Company being marked as “ACTIVE – non-compliant and Restrictions on filing certain forms (e.g., SH-7, PAS-3, DIR-12)
  • Companies must ensure all KMP and Auditor details are up to date.
  • Photographic evidence and GPS tagging of the registered office will increase enforcement scrutiny.

Non-Compliant Companies of Non-filing of Form INC-22A

  1. Classification as “ACTIVE – Non-Compliant” :

Such companies are flagged on the MCA portal, which restricts them from filing key forms, including SH-07 (Change in Authorized Capital). PAS-03 (Return of Allotment), DIR-12 (Change in Directors) and INC-22 (Change in Registered Office)

  1. Regulatory Action Under Companies Act, 2013

The government may initiate Show-cause notices, Financial penalties, Disqualification of directors (under Section 164), Strike-off proceedings under Section 248 for shell/inactive companies

  1. Risk of Blacklisting : Non-compliance may affect Creditworthiness, Tender eligibility, Banking relationships and FDI/VC funding opportunities

This probe is part of the government’s broader agenda to Weed out shell companies and benami structures, Enhance corporate governance and traceability, Enforce data integrity across statutory filings, Strengthen India’s compliance regime ahead of international reviews (e.g., FATF assessments)

Action Steps for Compliance filing of Form INC-22A

Task Timeline
Review KMP, Auditor, and Director records Immediate
Confirm filings of AOC-4 and MGT-7 for FY 2017-18 Before July 14, 2025
Capture and geotag registered office photos Prior to filing
Prepare DSCs for director and professional In advance
File INC-22A (ACTIVE) via MCA V3 portal From July 14, 2025

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