HomeServicesBusiness SetupPublic Limited Company Formation

Business Setup · Company & Entity Formation in India

Public Limited Company Formation

A Public Limited Company is the most powerful corporate structure available under Indian law — the only form that can raise capital from the general public, list on a recognised stock exchange, and offer securities freely to an unlimited number of shareholders.

Chartered Accountants · Chennai · Hyderabad · Bangalore · Dubai · Since 1986

2,000+Clients since 1986
42 yrsCA practice
4Offices · India & UAE
24 hrsResponse time

A Public Limited Company is the most powerful corporate structure available under Indian law — the only form that can raise capital from the general public, list on a recognised stock exchange, and offer securities freely to an unlimited number of shareholders. It is also the most demanding to operate: SEBI oversight, continuous disclosure obligations, and a compliance burden that increases sharply once you cross listing thresholds. At PNPC Global, we have advised founders, promoters, and CFOs on Public Limited Company formation, conversion from Private Limited, pre-listing restructuring, and annual compliance management since 1986. We do not just file your incorporation forms. We prepare your governance architecture — the MOA, AOA, board composition, internal controls, and compliance systems — to withstand the scrutiny that comes with public corporate life.

What it costs

Govt. feesGovernment & statutory fees as applicable to your case
Professional feeFixed professional fee — confirmed in writing before we start

No hidden charges. The exact figure is set in your engagement letter.

What Public Limited Company Formation is

Under Section 2(71) of the Companies Act 2013, a public company is defined as a company that is not a private company — meaning it does not restrict the right to transfer its shares, does not limit its number of members, and does not prohibit an invitation to the public to subscribe for its securities or debentures. A public company may have any number of shareholders. It must have a minimum of seven members and at least three directors. It can freely offer its shares and debentures to members of the public, subject to compliance with SEBI regulations if it is a listed company, and with the Companies Act 2013 prospectus provisions for unlisted public companies.

The critical distinction between a Public Limited Company and a Private Limited Company is not merely the number of shareholders — it is the legal permission to access public capital. A Private Limited Company is restricted to a closed circle of investors; a Public Limited Company may raise money from anyone, anywhere in India, provided it follows the statutory disclosure and prospectus regimes. This makes a Public Limited Company the natural final destination for businesses that plan to list on the BSE, NSE, or any recognised stock exchange, or that wish to raise deposits from the public, issue debentures to the public, or become the holding structure for a large multi-shareholder enterprise.

For regulatory purposes, every subsidiary of a public company is itself deemed to be a public company, regardless of what its own constitutional documents say. This means founders building a group structure — a holding company with operating subsidiaries — must factor in the compliance obligations of a public company for every entity in the group if the holding company is public. This is not a theoretical nuance; it directly affects audit requirements, disclosure obligations, board composition requirements, and capital-raising permissions for every company in the group.

An unlisted public company and a listed public company are both 'Public Limited Companies' under the Companies Act 2013, but they operate under dramatically different regulatory regimes. An unlisted public company must comply with the Companies Act 2013 in full — including mandatory statutory audit, more complex share transfer provisions, and more stringent governance requirements than a Private Limited Company — but it is not subject to continuous SEBI disclosure requirements. A listed public company is subject to all of the above plus SEBI (LODR) Regulations 2015, SEBI (ICDR) Regulations 2018 for new issues, mandatory corporate governance reports, quarterly financial results, related party transaction approvals, independent director requirements, and stock exchange reporting. The decision to operate as a public company therefore carries governance obligations from Day 1, not just from the date of listing.

When a Public Limited Company is the right structure

Planning an IPO — listing on BSE, NSE, SME Platform, or any recognised stock exchange requires the entity to be a Public Limited Company

Raising capital from the general public via prospectus, rights issue, or public debenture offering — legally requires a Public Limited Company form

Building a large-member business where the 200-shareholder ceiling of a Private Limited Company is insufficient — e.g. employee stock ownership with a large workforce, cooperative-style structures, or broad-based family businesses

Converting an existing Private Limited Company ahead of an IPO or institutional listing process — the conversion itself requires becoming a Public Limited Company before SEBI registration

Operating as a Non-Banking Financial Company (NBFC), infrastructure company, or other sector where regulators require or strongly prefer the public company form

Subsidiary of a foreign listed company where the parent's global governance standards require a public company structure in India

Businesses accepting public deposits under Section 73 of the Companies Act 2013 — only public companies satisfying specific eligibility criteria may accept deposits from members of the public

Promoter groups seeking to give early employees, strategic partners, or community stakeholders freely transferable equity without the restriction-of-transfer requirement that applies to Private Limited Companies

When a Public Limited Company is likely wrong for you

Early-stage startup with no immediate IPO plan and fewer than 200 shareholders — a Private Limited Company is faster, cheaper to run, and has a simpler compliance burden; convert to Public when the listing plan is concrete

Professional services firm (law, CA, architecture, consulting) — LLP is typically more appropriate; public company governance overhead is rarely justified in a partnership-model business

Solo or family-controlled business with no intention of ever diluting to public shareholders — OPC or Private Limited Company with appropriate family governance provides adequate protection without public company compliance cost

Businesses sensitive to the deemed-public-subsidiary rule — if any operating subsidiary would become a public company by association with a public holding entity, and that subsidiary is not ready for public company obligations, the structure requires careful advance planning

Founders who want to maintain full information confidentiality — public companies face disclosure requirements that Private Limited Companies do not; unlisted public companies must still file audited accounts that are publicly accessible on MCA

Structure Comparison

How Public Limited stacks up against alternatives

FeaturePublic LtdPvt LtdLLPOPC
Minimum members7 shareholders2 shareholders2 partners1 member
Maximum membersUnlimited200 shareholdersUnlimited1 member
Minimum directors3 directors2 directorsN/A (designated partners)1 director
Personal liabilityProtected to paid-up capitalProtected to paid-up capitalProtected to contributionProtected to paid-up capital
Public capital raisingYes — prospectus, IPO, NCDs to publicNo — closed circle onlyNoNo
Stock exchange listingYes — BSE, NSE, SME PlatformNot permitted (must convert first)NoNo
Share transferabilityFreely transferable (subject to AOA)Restricted by ArticlesNot shares — contribution transfer restrictedNon-transferable
SEBI oversight (if listed)Yes — LODR, ICDR, PIT regulationsNoNoNo
Minimum directors independent (if listed)As per SEBI LODR — at least 1/3 of boardNot applicableNot applicableNot applicable
Statutory auditAlways mandatoryAlways mandatoryAbove ₹40L turnoverAlways mandatory
Effective tax rate~25.17% (Sec 115BAA)~25.17% (Sec 115BAA)~30% + remuneration deduction~25.17%
Annual MCA filingsAOC-4, MGT-7, plus listed-entity disclosuresAOC-4, MGT-7Form 8, Form 11AOC-4, MGT-7
Minimum board meetings per year4 board meetings (Section 173)4 board meetings (Section 173)No mandatory meetings1 meeting (simplified)
Annual General MeetingWithin 6 months of FY end — mandatoryWithin 6 months of FY end — mandatoryNot requiredNot required
FDI eligibilityMost sectors — automatic routeMost sectors — automatic routeRBI approval in some sectorsNot permitted
Compliance cost (annual estimate)High — ₹2L–₹6L+ for unlisted; higher for listedModerate — ₹70K–₹1.8LLower — ₹40K–₹1.2LLow — ₹40K–₹80K

Compliance costs above are indicative for companies with up to ₹5 crore in turnover. Listed public companies face SEBI quarterly reporting, internal audit, secretarial audit, and corporate governance obligations that add materially to cost. The right structure depends on your capital-raising roadmap, timeline to listing, board composition, and sector.

How it works
#Stage & What PNPC DoesCA Advice Portals Never GiveTimeline
1Pre-Incorporation Strategy — Full business model and listing-readiness consultationWe start with the question portals never ask: Is a Public Limited Company actually right for you today, or should you incorporate as Private Limited and convert when you have a concrete listing date? We assess your funding roadmap, shareholding structure, sector, and governance readiness. Many promoters form a Public Limited Company years before they need it, accumulating unnecessary compliance overhead. Others wait too long and then scramble to convert with inadequate preparation time. The right timing depends on your specific situation.Day 1 — Senior CA consultation, 90 minutes minimum
2Name Clearance — MCA, Trademark, and sectoral approval checkA Public Limited Company name must end with 'Limited' (not 'Pvt. Ltd.'). Certain words — National, India, Bharat, Government, Enterprise, Industrial, Bank, Finance — require special Ministry approval or generate RoC scrutiny. We run simultaneous MCA, IP India trademark, and sectoral word restriction checks. We also check your preferred name against any existing listed company names to avoid confusion objections from SEBI at a later stage.Day 2–4 — 2 name options submitted simultaneously via SPICe+ Part A or RUN
3MOA Drafting — Objects clause structured for your current and future activitiesThe Memorandum of Association for a Public Limited Company requires the same precision as for a Private Limited Company, with additional considerations: if you plan to accept public deposits, the objects must support it; if you plan a specific line of business requiring a regulatory licence (NBFC, insurance intermediary, infrastructure), the objects must use the precisely correct statutory language. A generic objects clause may survive incorporation but create problems at SEBI registration or RBI licence application.Day 3–6 — Drafted and reviewed by senior CA. Client review cycle before submission.
4AOA Drafting — Governance architecture for a public companyThe Articles of Association for a Public Limited Company cannot import the same restricted-transfer and limited-member provisions that define a Private Limited Company's AOA. The AOA must address: share capital and class rights, rights of free transferability, quorum for general meetings (minimum 5 members for public company vs 2 for private), proxy rights, dividend declaration process, and (for pre-listing stage) any special reserved-matters provisions agreed with anchor investors or PE funds. We draft this from scratch — not from a template.Day 3–6 — Parallel with MOA drafting
5DSC Procurement and DIN for All DirectorsAll 3 or more directors require a Digital Signature Certificate. Directors who do not already have a DIN receive one via the SPICe+ process itself. Foreign directors need their identity documents apostilled and face additional verification requirements. For promoters incorporating from the UAE or other GCC countries, PNPC's Dubai office coordinates the apostille and identification document chain to eliminate back-and-forth with Indian embassies.Day 4–8 — Coordinated by PNPC across all directors including NRI/foreign directors
6SPICe+ Filing — Complete integrated filing with PAN, TAN, GST, EPFO, ESIC, PTSPICe+ is the single integrated form covering company name reservation, MOA, AOA, DIN allotment, PAN, TAN, GST, EPFO, ESIC, and (in some states) Professional Tax registration. We prepare, review, and submit the complete form. All director declarations, subscriber sheets, and MOA/AOA are attached as authenticated documents. We manage all MCA queries in real time — they arise on average in 20–30% of filings, most from address or name similarity issues that we pre-screen but cannot fully prevent.Day 7–18 — Certificate of Incorporation (COI) issued with CIN after MCA approval
7INC-20A — Commencement of Business DeclarationThis is the post-incorporation obligation most commonly missed. INC-20A certifies that all subscribers have paid up their share capital and that a bank account has been opened in the company's name. It must be filed within 180 days of the COI date. For a Public Limited Company with 7 or more subscribers, coordinating capital payment from all subscribers into the company bank account before the bank account is formally opened requires careful sequencing. PNPC manages this coordination and files INC-20A proactively — not on the last day.Within 180 days of COI — PNPC initiates at Day 90 of the 180-day window
8First Statutory Audit Setup — Auditor appointment and accounting frameworkAuditor appointment (Form ADT-1) must be made within 30 days of incorporation. For a Public Limited Company, the first auditor is appointed by the Board to hold office until the conclusion of the first AGM; the auditor appointed at that AGM then holds office for a five-year term without needing annual re-ratification (the annual AGM-ratification requirement was removed by the Companies (Amendment) Act 2017). The accounting system setup at this stage is critical: chart of accounts, cost centre structure, inter-company transaction framework if there is a group, and TDS compliance calendar. Errors in Year 1 accounting are typically discovered only at the first statutory audit — by which point correction is expensive.Within 30 days of COI — ADT-1 filed automatically by PNPC
9First AGM Setup and Secretarial InfrastructureA Public Limited Company must hold its first Annual General Meeting within 9 months of the close of its first financial year (for the first year only; thereafter within 6 months). All AGM procedures must comply with the Companies Act 2013 — notice periods, quorum, proxy, ordinary and special resolutions, and minutes. For a company planning to list, the AGM also provides the first opportunity for public-company governance practices to be formally recorded. PNPC sets up your secretarial infrastructure — board meeting templates, AGM notices, resolution drafting, and minutes — from Day 1.Ongoing — first AGM typically 9–15 months after incorporation
10Promoter Restructuring and Cap Table Clean-Up for Pre-Listing CompaniesFor companies converting from Private Limited or restructuring in advance of an IPO, the cap table must be clean: all share allotments documented, all transfers properly stamped and recorded, no unofficial share arrangements, no pending regulatory filings. SEBI's DRHP review process will expose every historical cap table irregularity. PNPC conducts a thorough historical MCA filing audit and recommends corrections before any SEBI engagement begins.Pre-listing stage — typically 18–36 months before IPO filing
11SEBI Liaison and DRHP Preparation Support (for IPO-track companies)The Draft Red Herring Prospectus (DRHP) is the cornerstone document for an IPO. PNPC's role in DRHP preparation is the financial statements, accounting policies, related party transaction disclosure, and working capital statement that investment bankers require. We work alongside your investment bank and legal counsel as the CA firm of record — preparing the audited financial statements, reports required under SEBI (ICDR) Regulations, and responding to SEBI observations on financial matters.IPO track — typically begins 12–24 months before target listing date
12Post-Listing Compliance Management (for listed companies)Listed companies face quarterly financial result filings (within 45 days of quarter end, 60 days for annual), continuous disclosure obligations, related party transaction approvals, insider trading compliance (PIT Regulations), board composition maintenance (SEBI LODR Chapter IV), annual secretarial audit (Form MR-3), annual internal audit, and SEBI-mandated corporate governance reports. PNPC manages the full compliance calendar as a retained engagement — each obligation initiated in advance, none missed.Year-round — every quarter, every year after listing

Incorporation timeline: COI typically within 15–20 working days of SPICe+ submission, assuming documents are in order. End-to-end from first consultation to fully operational company: 5–8 weeks. IPO track timelines are substantially longer and depend on financial year-end audit cycles, SEBI processing time, and market conditions.

Document Checklist
For Each Director (minimum 3 required)

PAN Card — self-attested. The name on PAN must exactly match the name on Aadhaar — even a single character mismatch causes DSC verification failure and delays the entire filing

Aadhaar Card — must be linked to an active mobile number for OTP-based video verification

Passport-sized photograph — white background, taken within the last 3 months

Proof of current residential address — electricity bill, water bill, or bank statement dated within the last 2 months. Rental agreement alone is not accepted by MCA as standalone address proof

Personal email ID — not a shared business address — used for DIN registration, MCA portal, and income tax communications

Mobile number linked to Aadhaar for OTP verification

Declaration in Form DIR-2 (consent to act as director) and Form INC-9 (declaration by subscriber/director) — PNPC prepares both and coordinates execution

For NRI directors: Valid passport apostilled by the Indian Embassy in the country of residence + overseas address proof notarised by a local notary authority

For foreign national directors (non-Indian citizen): All identity and address documents apostilled by the competent authority in the home country — PNPC coordinates the specific requirements by country

DIN (Director Identification Number) — if not already held, obtained through the SPICe+ process itself; PNPC tracks and coordinates this for each director

For Each of the 7 Minimum Subscriber-Shareholders

PAN Card and Aadhaar for all individual subscribers

Current residential address proof — utility bill or bank statement within 2 months

Subscriber sheet of MOA and AOA — signed with wet signature in the correct format specified by MCA; PNPC prepares the subscriber sheets and coordinates execution across all 7+ subscribers

Declaration under Form INC-9 (declaration of subscriber) — prepared and coordinated by PNPC

For corporate subscribers (Indian companies): Board Resolution authorising the subscription + Certificate of Incorporation + PAN of the subscribing company + authorised signatory identity and address proof

For foreign corporate subscribers: Certificate of Incorporation from the home jurisdiction + Board Resolution authorising the subscription + authorised signatory identity proof — all apostilled or notarised as per the home country's process. Foreign subscriber investment constitutes FDI and requires Form FC-GPR within 30 days of share allotment

Bank account details for each subscriber — required to demonstrate payment of subscription money into the company's account before INC-20A is filed

For the Registered Office

Utility bill in the property owner's name (electricity, gas, telephone) — dated within the last 2 months. Bills older than 2 months are rejected by MCA

If rented: Registered rent agreement + No Objection Certificate (NOC) from the property owner — the NOC must be on the owner's letterhead with original signature; verbal or email consent is not accepted

If the registered office is in a property owned by a director or promoter: Sale deed or property tax receipt in their name + NOC from that individual

If using a virtual or co-working office: Rent agreement from the virtual office provider + their NOC on company letterhead — PNPC can recommend verified virtual office providers in Chennai, Bangalore, and Hyderabad where RoC address verification is consistently clean

Address must be an actual physical address — P.O. Box addresses are not accepted by MCA for company registered office

Note: The registered office can be changed after incorporation but each change requires a Board resolution, RoC filing, and payment of applicable fee — getting it right at incorporation avoids this administrative cost

Constitutional and Business Information

2–3 proposed company names in order of preference, along with the significance of each name — PNPC conducts a multi-layered clearance check (MCA, IP India, listed company names, restricted words) before submitting

Detailed plain-language description of business activities — PNPC translates this into the legally precise MOA objects clause, covering current activities and foreseeable future diversification without creating unnecessarily broad objects that invite RoC query

Proposed authorised share capital and issued share capital at incorporation — for a Public Limited Company, the authorised capital must accommodate not just the current 7 subscribers but any pre-IPO investor rounds, ESOP schemes, and public issue tranches. PNPC advises the appropriate authorised capital based on your roadmap

Proposed shareholding split and percentage for each of the 7+ founding subscribers — this is the founding cap table; for pre-IPO companies, PNPC reviews it for promoter holding adequacy (SEBI requires minimum promoter holding post-IPO), lock-in compliance, and investor-readiness

Details of any class rights, preference shares, or convertible instruments proposed — the AOA and MOA must accommodate these from Day 1 or amendment costs arise later

Financial year — April to March strongly recommended for alignment with Indian tax and audit cycles

Main industry / sector — determines if any additional regulatory licences are required alongside incorporation (RBI for NBFC, IRDA for insurance, SEBI for intermediaries)

For Pre-Listing and IPO-Track Companies

Audited financial statements for all prior years — SEBI DRHP requires 3 years of restated, ICAI-compliant financial statements prepared under the supervision of the statutory auditor

Details of all historical share allotments, transfers, and buybacks — PNPC conducts an MCA filing audit to verify every historical share transaction is reflected correctly in the company's MCA records before SEBI engagement

Existing shareholder agreements and investor agreements — reviewed by PNPC to identify provisions that conflict with Companies Act 2013 requirements applicable to a public company or SEBI LODR requirements applicable post-listing

Internal financial controls documentation — SEBI DRHP requires management's assessment of internal financial controls; PNPC assists in establishing the documented control framework required

List of all related parties and related party transactions for the prior 3 years — required for prospectus disclosure and reviewed by SEBI carefully

Existing intellectual property registrations (trademarks, patents, copyrights) — IP must be formally assigned to the company if it was developed by promoters personally; unassigned IP is a common SEBI query in DRHP filings

Litigation disclosure documentation — all pending legal proceedings, regulatory notices, and tax demands must be disclosed; PNPC assists in preparing the factual framework for the legal team to structure the disclosure

Post-Incorporation Governance Documents (PNPC Prepares)

First Board Meeting agenda and board resolutions — covering auditor appointment, bank account opening authority, signing authority designation, common seal (if adopted), and commencement of business declaration

Form ADT-1 — formal appointment of statutory auditor, filed within 30 days of incorporation

INC-20A — Commencement of Business Declaration, filed within 180 days of COI date

Statutory registers — Register of Members, Register of Directors and KMP, Register of Charges, Register of Contracts with Related Parties (Form MBP-1) — PNPC sets these up in proper format from Day 1

Annual compliance calendar populated for the first financial year — every Board meeting date, AGM window, AOC-4 and MGT-7 due dates, TDS quarterly dates, GST filing schedule, and DIR-3 KYC deadline

Minute book setup for Board and general meetings — all minutes drafted by PNPC from first meeting, signed within the statutory time limit

Ongoing obligations
PhaseTriggered ByPNPC CA GuidanceRisk If Ignored
Structure Decision (Pre-incorporation)Intent to form a public companyMost critical decision point. Should you incorporate as Public Ltd now, or as Private Ltd and convert? The conversion route is viable but involves stamp duty, MCA filings, shareholder approvals, and a gap period during which your company is technically transitioning. If you have a concrete listing date within 3 years, incorporate Public Ltd from Day 1 to avoid this cost. If the listing plan is beyond 3 years or uncertain, Private Ltd first is typically more efficient.Premature public company incorporation → 3–5 years of unnecessarily high compliance cost. Delayed conversion → inadequate preparation time before SEBI DRHP submission.
Incorporation (Day 1–30)Decision confirmed, structure chosenName clearance (MOA, trademark, listed companies), MOA objects drafted for public company, AOA drafted with public company-appropriate governance, DSC for all 3+ directors, SPICe+ filed. For 7+ subscribers, subscriber sheets coordinated across all parties — a logistical challenge that portals cannot manage.Template MOA/AOA that require expensive amendment before first investor round. Missed DSC for a foreign director holds up entire filing.
Commencement (Day 30–180)COI receivedINC-20A coordination: all 7 subscribers must have paid subscription money into company bank account before filing. Bank account setup with authority matrix. Auditor appointment via ADT-1. GST registration. Accounting system setup from transaction #1. First Board Meeting.INC-20A missed → company cannot operate + company liable to a penalty of ₹50,000 + every officer in default liable to ₹1,000/day of continuing default (capped at ₹1 lakh per officer) under Section 10A(2) + strike-off risk. ADT-1 missed → additional MCA filing fees escalating with delay, plus exposure to penalty under Section 137.
First Year Operations (Month 1–12)Business activities beginQuarterly Board meetings (Section 173 — minimum 4 per year, no gap exceeding 120 days between two consecutive meetings). TDS on every applicable payment. GST compliance. Director remuneration structure. Advance tax. Annual audit preparation from Month 9.Board meeting gaps > 120 days → officer in default liable under Section 173. TDS defaults → 18% interest + penalty + disallowance of expense. GST mismatches → notices, penalties, blocked ITC.
First AGM (Month 9–15)End of first financial yearFirst AGM must be held within 9 months of the close of the first financial year (for subsequent years, 6 months). AOC-4 filed within 30 days of AGM, or 29 October whichever is earlier. MGT-7 filed within 60 days of AGM, or 29 November whichever is earlier. PNPC prepares all AGM documents — notice, agenda, director's report, auditor's report, financial statements.AGM not held → Section 96 violation, ₹1 lakh fine on company + ₹1 lakh fine on each officer in default + Registrar can call AGM. Late AOC-4/MGT-7 → ₹100/day/form, no cap.
Annual Compliance Cycle (Every Year)31 March FY endStatutory audit, ITR-6, AOC-4, MGT-7, four Board meetings, AGM, DIR-3 KYC by 30 September, TDS reconciliation, GST annual return, secretarial audit (if applicable threshold is met), internal audit (if threshold met). PNPC manages the full calendar proactively.₹100/day/form — no cap. Three consecutive default years → director disqualification under Section 164(2). Company becomes liable for MCA strike-off action.
Pre-IPO Restructuring (18–36 months before listing)Decision to file DRHP with SEBICap table audit — every share allotment, transfer, and ESOP exercise traced and verified. All MCA filings current. Promoter holding structure reviewed for SEBI minimum holding compliance. Related party transactions documented. IP assigned to company. Internal financial controls framework established. Statutory audit reports for 3 years restated if needed under SEBI ICDR.Undisclosed historical share transfer discovered in SEBI review → DRHP rejection or delay. Missing MCA filing → RoC must regularise before SEBI can proceed. IP not assigned → SEBI observation on material asset not owned by issuer.
SEBI DRHP Filing and ReviewDRHP submitted to SEBIPNPC prepares financial statements in the format required by SEBI ICDR Regulations 2018 (Chapter III — disclosures). Responds to SEBI observations on financial and accounting matters. Working capital statement, capitalisation statement, issue proceeds utilisation schedule — all prepared by PNPC in coordination with investment bankers. Certificate of financial statements by statutory auditor filed with SEBI.SEBI observations on financial statements delay the IPO by months. Errors in working capital statement require refiling. Incorrect promoter contribution disclosures require amendment.
IPO Open PeriodSEBI approval received, listing schedule setRed Herring Prospectus (RHP) financial data finalised and certified. ASBA mechanism set up through bankers. Price band financial modelling inputs provided. PNPC reviews all financial statements in the final RHP before submission to stock exchanges.Last-minute financial statement error in RHP → regulatory action. Undisclosed related party in RHP → investor complaint, SEBI investigation.
Post-Listing — Listed Company ComplianceListing on BSE / NSESEBI LODR obligations: board composition maintained (minimum independent directors), audit committee, nomination and remuneration committee, stakeholders' relationship committee. Quarterly financial results within 45 days of quarter end (standalone + consolidated). Annual report within 60 days of AGM. Continuous disclosure of material events. Annual secretarial audit. Related party transaction approvals at board and shareholder level. Insider trading compliance (PIT Regulations 2015).Delayed quarterly results → stock exchange fine + SEBI enforcement. Insider trading violation → criminal prosecution under SEBI Act + civil penalties. Undisclosed material event → SEBI investigation + investor liability.
Rights Issues and Further Public OffersNeed for additional capital post-listingRights issue under Section 62 read with SEBI ICDR Regulations. Bonus issue resolution and capitalisation. Further Public Offer (FPO) if large capital raise. Qualified Institutional Placement (QIP) for faster institutional capital. PNPC assists in preparing the financial statements and accountant's certificate required for each offer document.Non-compliant share allotment → void allotment, refund obligation, SEBI action. Missing FC-GPR for foreign subscriber share allotment → RBI compounding.
Conversion from Private Limited (if applicable)Private Limited converting to Public Limited ahead of IPOConversion requires: special resolution of shareholders, amendment to MOA and AOA to remove all private company restrictions, change to name (drop 'Private', add 'Limited'), RoC filing of Form INC-27 with Altered MOA/AOA, new Certificate of Incorporation from RoC, compliance with all public company requirements from date of conversion. PNPC manages the full conversion process — shareholder meeting, MOA/AOA amendment, RoC filing.Conversion not completed before SEBI DRHP filing → SEBI cannot process. AOA still containing private company restrictions post-conversion → invalid public company constitution.
Frequently asked
What is a Public Limited Company in plain terms — and how does it differ from a Private Limited Company?

A Public Limited Company is a corporate entity that can freely offer its shares and raise capital from any member of the public. A Private Limited Company can only offer shares to a closed group of known investors and is restricted to a maximum of 200 shareholders. The Public Limited Company removes both these restrictions — unlimited shareholders, no restriction on transfer, and the legal ability to issue a prospectus inviting public subscription. The formal name must end with 'Limited' rather than 'Private Limited'.

Practitioner noteThe most common misconception is that all public companies are listed. They are not. Many companies operate as unlisted Public Limited Companies — with more shareholders and more compliance than a Pvt Ltd, but without SEBI oversight and without stock exchange listing. Whether you need the public company form depends entirely on your capital structure plans, not on whether you are listed today.
What is the minimum number of shareholders and directors required for a Public Limited Company?

Minimum 7 shareholders (members) and minimum 3 directors. There is no maximum on shareholders. At least one director must be an Indian resident — a person who has been physically present in India for at least 182 days in the previous calendar year — as required under Section 149(3) of the Companies Act 2013.

Practitioner noteCoordinating 7 subscriber-shareholders for the founding documents is the single largest logistical challenge of incorporating a Public Limited Company. Every subscriber must sign the subscriber sheet of the MOA, and all 7 must pay up their subscription before INC-20A can be filed. We have seen incorporations delayed by 4–6 weeks simply because one of the 7 founding subscribers was unavailable, out of the country, or needed their documents apostilled. Plan this ahead.
Is there a minimum paid-up capital requirement for a Public Limited Company?

No. The Companies (Amendment) Act 2015 removed the minimum paid-up capital requirement for both Private Limited and Public Limited Companies. You may incorporate a Public Limited Company with any amount of paid-up capital, even ₹7 (₹1 per subscriber). In practice, your authorised share capital — the ceiling stated in your MOA — determines the stamp duty payable at incorporation and should be set to accommodate your projected share issuances for the next 18–24 months.

Practitioner noteFor companies on an IPO track, the authorised share capital typically needs to accommodate not just existing investors but pre-IPO allotments, ESOPs, and the public issue itself. Setting authorised capital too low requires a shareholder special resolution and stamp duty on the increase — a cost and delay you can avoid by anticipating your capital needs at incorporation.
Can I first incorporate as a Private Limited Company and later convert to a Public Limited Company before my IPO?

Yes. Conversion from Private Limited to Public Limited is a well-defined process under Section 14 and 18 of the Companies Act 2013. It requires: a special resolution of shareholders to alter the MOA and AOA removing all private company restrictions, a name change (dropping 'Private'), and filing Form INC-27 with the Registrar of Companies. The RoC issues a new Certificate of Incorporation confirming the conversion. Once converted, all Public Limited Company obligations apply immediately.

Practitioner noteMost IPO-bound companies we work with incorporate as Private Limited Companies first and convert 24–36 months before the target listing date. This is almost always more cost-effective than carrying public company compliance overhead during the early growth years when the listing plan is not yet confirmed. Conversion costs — stamp duty on amended documents, MCA filing fees, legal costs — are typically well below 3 years of avoided public company compliance overhead.
Does a Public Limited Company automatically become eligible to list on a stock exchange?

No. Being a Public Limited Company is a necessary condition for listing, not a sufficient one. To list on BSE or NSE, you must additionally comply with SEBI (ICDR) Regulations 2018 — which govern the public issue process — and satisfy the listing eligibility criteria of the specific exchange, which include minimum net worth, track record, post-issue paid-up capital, and other exchange-specific requirements. For SME platforms (BSE SME, NSE Emerge), there are separate entry criteria with lower thresholds than the main board.

Practitioner noteMany companies are surprised to learn that there is no direct path from Public Limited Company registration to listing. SEBI's DRHP review process alone takes several months from submission to approval, and requires audited financials for the prior 3 years, a merchant banker (lead manager), a registrar, a legal counsel, and significant preparatory work. We strongly recommend engaging a CA firm with IPO experience — such as PNPC — 18–24 months before your target listing date.
What is the SPICe+ process for Public Limited Company incorporation — and how does it work?

SPICe+ (Simplified Proforma for Incorporating Company electronically Plus) is the single integrated MCA form for company incorporation. It covers: name reservation (Part A), company registration with MOA and AOA (Part B), PAN and TAN allotment, GST registration, EPFO and ESIC registration, and in some states, Professional Tax registration. For a Public Limited Company, all 7 subscribers must sign the subscriber sheets either physically or via DSC, and all 3+ directors must have valid DSCs. PNPC prepares, reviews, and submits the entire SPICe+ filing and manages all MCA queries until the Certificate of Incorporation is issued.

What is INC-20A — and what are the consequences of missing it for a Public Limited Company?

INC-20A is the Declaration of Commencement of Business — a certificate signed by a director confirming that every subscriber has paid the value of shares agreed to, and that a bank account has been opened in the company's name. It must be filed within 180 days of the date of incorporation. Without a valid INC-20A, the company cannot lawfully commence any business or exercise any borrowing powers. Under Section 10A(2), the company is liable to a penalty of ₹50,000, and every officer in default is liable to a penalty of ₹1,000 for each day the default continues, subject to a maximum of ₹1,00,000 per officer. The company is also vulnerable to MCA action for strike-off.

Practitioner noteFor a Public Limited Company with 7 or more founding subscribers, coordinating payment from every subscriber into the company bank account — before the bank account has even been formally set up — is a chicken-and-egg problem that catches founders off-guard. We sequence the bank account opening and the subscription payment collection carefully, and track the INC-20A deadline from Day 1. We initiate the filing ourselves at Day 90 of the 180-day window.
How many board meetings is a Public Limited Company required to hold each year?

A minimum of 4 board meetings per year, with no gap exceeding 120 days between two consecutive meetings, as required under Section 173(1) of the Companies Act 2013. This applies to both listed and unlisted public companies. The first board meeting must be held within 30 days of the date of incorporation. Notice of at least 7 days must be given to all directors for each meeting (shorter notice permitted with consent of directors). Every meeting must have proper agenda, quorum, and minutes signed within 30 days.

Practitioner noteA gap exceeding 120 days between two consecutive board meetings, or a failure to give the statutory notice of a board meeting, puts every officer whose duty it was to give notice at risk of a penalty under Section 173(4) of the Companies Act 2013 — currently a flat penalty of ₹25,000 per defaulting officer. For clients on annual retainer with PNPC, we schedule all 4 board meeting dates at the start of the financial year and circulate draft agendas and notices in advance of each meeting.
When must a Public Limited Company hold its Annual General Meeting?

The AGM must be held within 6 months of the close of the financial year (Section 96 of the Companies Act 2013). For a company with a March 31 financial year end, the AGM must be held by September 30. For the first AGM after incorporation, a company may have up to 9 months from the close of its first financial year. The time gap between two successive AGMs must not exceed 15 months. Failure to hold an AGM allows any member to apply to the Tribunal to call one, and attracts penalties on the company and its officers.

Practitioner noteThe AGM for a Public Limited Company involves more complexity than for a Private Limited Company — longer statutory notice period (typically 21 days), the right of members to demand a poll, proxy rights, and (for listed companies) remote e-voting obligations. PNPC prepares the notice, agenda, directors' report, auditor's report, and all AGM-related resolutions as part of our secretarial services engagement.
What annual filings must a Public Limited Company submit to the Registrar of Companies?

Mandatory annual MCA filings include: AOC-4 (Annual Financial Statements) — within 30 days of AGM, or 29 October whichever is earlier; MGT-7 (Annual Return) — within 60 days of AGM, or 29 November whichever is earlier; DIR-3 KYC — for each director, by 30 September; MSME Form I — if outstanding dues to MSME vendors exceed 45 days, by 31 October and 30 April; and any other event-based filings arising during the year. For listed companies, SEBI LODR requires additional filings to the stock exchange — quarterly financial results within 45 days, annual report within 60 days of AGM, and various event-based disclosures.

Practitioner noteThe penalty for late MCA filing is ₹100 per day per form with no maximum cap. A company that misses AOC-4 and MGT-7 for a single year and takes 6 months to regularise accumulates approximately ₹36,500 in late filing fees on those two forms alone — before professional fees for the regularisation work. We build a proactive calendar for every client and initiate each filing well before the due date.
Is a statutory audit mandatory for a Public Limited Company?

Yes. Statutory audit under Section 139 of the Companies Act 2013 is mandatory for every Public Limited Company, regardless of turnover, paid-up capital, or activity level — including dormant companies and companies in their first year of operations. The statutory auditor must be a Chartered Accountant or a firm of Chartered Accountants holding a valid Certificate of Practice from ICAI. The first auditor must be appointed by the Board within 30 days of incorporation (via Form ADT-1) and holds office until the conclusion of the first AGM; the auditor appointed at the AGM thereafter holds office for a five-year term (subject to rotation limits) without requiring annual ratification at each subsequent AGM — the annual-ratification requirement in the original Section 139(1) proviso was removed by the Companies (Amendment) Act 2017. Under Section 139(2), for listed companies and other specified public companies: an individual auditor cannot be appointed for more than one term of 5 consecutive years; an audit firm cannot be appointed for more than two terms of 5 consecutive years (i.e. 10 years in total), after which rotation to a new auditor is mandatory.

Practitioner noteAuditor rotation requirements — mandatory for listed companies and certain other specified classes of public companies — mean that a founder or promoter cannot appoint the same CA firm for the life of the company. For clients approaching the maximum tenure, we help with a structured transition to a successor auditor that does not disrupt the audit timeline.
Is a secretarial audit required for Public Limited Companies?

Under Section 204 of the Companies Act 2013, a secretarial audit by a Practising Company Secretary (PCS) in Form MR-3 is mandatory for: every listed company; every public company with paid-up share capital of ₹50 crore or more; and every public company with a turnover of ₹250 crore or more. The secretarial audit report must be annexed to the Board's Report presented at the AGM. Additionally, as per a 2020 amendment, certain companies are required to appoint a whole-time Company Secretary (CS) as a Key Managerial Personnel.

Practitioner noteSmaller unlisted Public Limited Companies below the paid-up capital and turnover thresholds are not required to conduct a secretarial audit. However, many opt for one voluntarily before an IPO or external investment, as it provides a clean compliance certificate that satisfies investor due diligence requirements.
What is the role of the SEBI (LODR) Regulations 2015 for a listed Public Limited Company?

SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015 — known as LODR — govern every company listed on a recognised stock exchange in India. Key obligations include: board composition requirements (minimum number of independent directors, at least one woman director); mandatory committees (audit committee, nomination and remuneration committee, stakeholders' relationship committee for listed companies with paid-up capital above ₹10 crore); quarterly financial results to the exchange within 45 days of quarter end; annual report within 60 days of AGM; continuous disclosure of material events (Regulation 30); related party transaction approvals; and the Corporate Governance Report submitted annually. These obligations begin from the date of listing, not from the date of filing the DRHP.

Practitioner noteSEBI LODR compliance is a full-time function for mid-size listed companies. It requires a dedicated compliance officer, a mechanism for board and committee meetings to comply with quorum requirements, and systems for real-time disclosure of material events. Many mid-size listed companies retain a CA firm and a PCS together to manage these obligations. PNPC provides the CA-side of this engagement — financial disclosures, audit, and SEBI financial reporting — as a retained function.
What is the SEBI (PIT) Regulations 2015 — and does it apply to all Public Limited Companies?

SEBI (Prohibition of Insider Trading) Regulations 2015 apply specifically to listed companies and their designated persons — directors, officers, KMPs, and any person in possession of unpublished price sensitive information (UPSI). All such persons must be on the company's insider trading compliance list, are prohibited from trading during trading windows that are closed, and must pre-clear trades above specified thresholds. Violations attract criminal prosecution under the SEBI Act, disgorgement of profits, and monetary penalties. Unlisted public companies are not subject to PIT Regulations.

Practitioner noteWe advise companies approaching listing to implement a written insider trading policy at least 12–18 months before the IPO date, both as good governance and to demonstrate to SEBI that the company's internal controls were in place before listing. Companies that implement this policy on the date of listing often discover gaps immediately.
Can a foreigner or NRI be a director or shareholder of a Public Limited Company in India?

Yes. Foreign nationals and NRIs can be directors and shareholders of a Public Limited Company in India. At least one director must be a resident Indian (182 days in India in the previous calendar year). Foreign national directors need their identity documents apostilled and must comply with DSC video verification requirements. NRI and foreign shareholders investing by way of subscription to shares are making Foreign Direct Investment (FDI) under FEMA — Form FC-GPR must be filed with the RBI-authorised dealer bank within 30 days of each allotment.

Practitioner noteFor companies with a mix of resident Indian and NRI/foreign founders, the INC-20A subscription payment coordination is more complex — international bank transfers must be structured and timed to arrive before the INC-20A filing deadline. PNPC's Dubai office provides direct on-ground support for UAE-based promoters navigating this.
Does a Public Limited Company need to comply with Foreign Exchange Management Act (FEMA) provisions?

Yes, whenever foreign investment or overseas transactions are involved. Key FEMA compliance for a Public Limited Company includes: Form FC-GPR within 30 days of share allotment to any non-resident or foreign investor; Annual Return on Foreign Liabilities and Assets (FLA Return) filed by 15 July if there is any outstanding FDI or ODI; FCTRS for secondary transfer of shares between resident and non-resident; and compliance with pricing guidelines under FEMA (Non-Debt Instruments) Rules 2019. Any contravention of FEMA provisions attracts compounding proceedings and penalties.

Practitioner noteThe FC-GPR deadline of 30 days from allotment is the most commonly missed FEMA obligation. It is triggered automatically with every share allotment to a foreign investor — including at the time of an IPO if a foreign institutional investor subscribes. PNPC tracks every allotment event and files FC-GPR without waiting for the client to remind us.
What is a prospectus — and when is it required?

A prospectus is a document issued by a Public Limited Company inviting members of the public to subscribe to its shares or debentures. Under the Companies Act 2013, a Public Limited Company intending to offer securities to the public must issue a prospectus prepared in accordance with the requirements of Section 26 and the SEBI (ICDR) Regulations 2018 (for listed company offers). The prospectus must disclose all material information about the company, including financial statements, risk factors, and use of proceeds. There is also a 'shelf prospectus' mechanism for companies making repeated public issues. An unlisted public company raising money from members only (rights issue) does not need a prospectus but must still comply with Section 42 (private placement) requirements if it is a private placement.

Practitioner noteA Draft Red Herring Prospectus (DRHP) filed with SEBI is the precursor to the final Red Herring Prospectus (RHP) and the Prospectus. The transition from DRHP to RHP to Prospectus involves multiple rounds of SEBI comments, financial statement updates, and legal review. The CA firm of record — which must certify the financial statements — is under pressure at each of these transition points.
What is the minimum notice period for an AGM of a Public Limited Company?

Under Section 101 of the Companies Act 2013, an AGM requires a minimum of 21 clear days' notice to all members, directors, and auditors, unless a shorter notice is consented to in writing by members holding at least 95% of the paid-up share capital. For listed companies, SEBI LODR additionally requires that the notice be sent at least 21 days before the AGM and filed with the stock exchange simultaneously. The notice must include the agenda, proxy form, and for listed companies with large membership, e-voting instructions.

Practitioner noteContrast this with a Private Limited Company AGM, where the 21-day notice requirement can often be waived by unanimous written consent of shareholders. For a Public Limited Company with many shareholders — including public shareholders post-listing — a shorter notice is practically impossible to obtain, so the 21-day window must be built into your AGM calendar.
What is the quorum for a board meeting and a general meeting of a Public Limited Company?

For board meetings: quorum is one-third of total directors or 2 directors, whichever is higher (Section 174 of the Companies Act 2013). For general meetings (including AGM) of a Public Limited Company, Section 103(1)(a) sets a tiered quorum based on membership as on the date of the meeting: 5 members personally present if the total number of members does not exceed 1,000; 15 members if the membership is more than 1,000 but up to 5,000; and 30 members if the membership exceeds 5,000. This compares to 2 members for a Private Limited Company regardless of size. If the quorum is not present within 30 minutes of the scheduled meeting time, the meeting stands adjourned to the same time and place the following week (unless the Articles provide otherwise). If quorum is again not present, members present constitute the quorum.

Practitioner noteThe higher quorum requirement for general meetings of public companies — starting at 5 members physically present and scaling up with membership size — can be challenging in practice for companies with a dispersed shareholder base, particularly listed companies with thousands of public shareholders. For pre-AGM planning, PNPC advises clients to confirm proxy arrangements and assess shareholder attendance patterns from prior meetings.
What is the difference between an ordinary resolution and a special resolution — and when does a Public Limited Company need each?

An ordinary resolution is passed by a simple majority of votes cast (more than 50%). A special resolution requires at least 75% of votes cast in favour. Ordinary resolutions suffice for routine matters: appointing directors, approving financial statements, declaring dividends. Special resolutions are required for: altering the MOA (changing name, objects, or capital), altering the AOA, voluntary winding-up, issuing shares with differential voting rights, buyback of shares, reduction of capital, and numerous other significant decisions. For listed companies, many related party transactions also require shareholder approval by ordinary resolution, with interested parties excluded from voting.

Practitioner noteFor companies converting from Private Limited to Public Limited, the conversion itself requires a special resolution. We advise clients to carefully assess whether all shareholders are likely to support the conversion before scheduling the extraordinary general meeting — a blocking minority can stall the process.
What is a Promoter for a listed Public Limited Company, and what are the lock-in obligations?

A 'promoter' under SEBI (ICDR) Regulations 2018 includes persons who have been instrumental in the formation of the company, who hold or control shares in the company, and who are named as promoters in the offer documents. In an IPO, shares held by promoters are subject to lock-in — a period during which they cannot be sold: minimum 18 months lock-in for the minimum required promoter contribution (typically 20% of post-issue paid-up capital), and 6 months lock-in for the balance of pre-IPO promoter holdings. Promoter holdings below the minimum required contribution threshold must be locked in for 6 months from the date of allotment in the IPO.

Practitioner notePre-IPO share transfers to promoters at a price below the issue price — which occurs in some cases where founders sell shares to a strategic investor before the IPO — can create issues around lock-in and valuation, and for pre-April 2025 issuances, historical Section 56(2)(viib) angel tax exposure (the provision was abolished prospectively from 1 April 2025 by the Finance Act 2024). These transactions should be reviewed by a CA with SEBI experience well before the IPO filing.
What was angel tax — Section 56(2)(viib) — and has it been abolished?

Section 56(2)(viib) of the Income Tax Act 1961 — commonly called 'angel tax' — was a provision that taxed, as income from other sources, any consideration received by a closely held company for issue of shares in excess of the fair market value of those shares. The Finance Act 2023 extended the provision to cover share issuances to non-residents as well. However, the Finance Act 2024 abolished Section 56(2)(viib) with effect from April 1, 2025 (Assessment Year 2025–26 onwards). Angel tax no longer applies to share issuances made on or after April 1, 2025. For share issuances made before that date, the provision may still be relevant for pending assessments or appeals. The repeal removes a significant compliance and valuation burden for startups, pre-IPO companies, and unlisted public companies raising capital.

Practitioner noteAlthough angel tax has been abolished prospectively, companies that received funding at high valuations in Assessment Years 2020–21 through 2024–25 may still face scrutiny under the repealed provision for those earlier years. If you have pending income tax assessments involving Section 56(2)(viib), speak to PNPC before responding — the transitional position requires careful handling.
What is the minimum number of independent directors a listed Public Limited Company must have?

Under SEBI LODR Regulation 17 and Section 149(4) of the Companies Act 2013: every listed public company must have at least one-third of its total directors as independent directors (rounded up where not a whole number). Additionally, the listed company must have at least one woman director. If the chairperson of the board is a non-executive director who is not a promoter or related to the promoter, the company may have one-third independent directors; otherwise the minimum rises to at least half the board. All independent directors must be registered on the Indian Institute of Corporate Affairs (IICA) online proficiency self-assessment test portal.

Practitioner noteMany mid-size promoter-led companies approach an IPO with a board comprising only promoter directors, and realise too late that they need to identify, onboard, and run multiple board meetings with new independent directors before SEBI will approve their DRHP. Identifying credible, available independent directors 12–18 months before listing — not 3 months before SEBI filing — is strongly advised.
Are there any mandatory committees required for a Public Limited Company?

Listed public companies must constitute: an Audit Committee (Section 177, SEBI LODR Regulation 18) with a majority of independent directors, chaired by an independent director, with at least one member having financial and accounting knowledge; a Nomination and Remuneration Committee (Section 178, LODR Regulation 19); a Stakeholders' Relationship Committee (Section 178(5), LODR Regulation 20) for companies with more than 1,000 shareholders. Companies with net worth above ₹500 crore or turnover above ₹1,000 crore or a net profit above ₹5 crore in the preceding financial year must also constitute a CSR Committee (Section 135).

Practitioner noteUnlisted public companies are subject to the Companies Act provisions for audit and nomination committees but not to the SEBI LODR overlay. For pre-listing companies, we recommend constituting these committees 12 months before the IPO target date to demonstrate operational governance to SEBI.
What are the key differences in compliance obligations between an unlisted Public Limited Company and a listed Public Limited Company?

An unlisted Public Limited Company must comply with the Companies Act 2013 in full: statutory audit, AGM, 4 board meetings per year, AOC-4, MGT-7, DIR-3 KYC, and applicable event-based filings. A listed Public Limited Company bears all of the above plus: SEBI LODR quarterly financial results filings, continuous event-based disclosures, corporate governance report, board composition requirements with independent directors, mandatory board committees, insider trading compliance (PIT Regulations), annual secretarial audit, and stock exchange compliance. Annual compliance cost for an unlisted public company is broadly in the range of ₹2–6 lakh depending on complexity; for a listed company it is significantly higher and depends on the size of the company and complexity of transactions.

Practitioner noteThe jump in compliance cost and effort from unlisted to listed is substantial. Companies that list without adequate compliance infrastructure in place routinely receive stock exchange notices within the first quarter for late results filings or incomplete disclosures. We build the compliance framework before listing, not after.
What is Corporate Social Responsibility (CSR) — and when does it apply to a Public Limited Company?

Under Section 135 of the Companies Act 2013, CSR obligations apply to any company — including Public Limited Companies — that in the immediately preceding financial year had: net worth of ₹500 crore or more, OR turnover of ₹1,000 crore or more, OR net profit of ₹5 crore or more. Qualifying companies must spend at least 2% of the average net profit of the preceding 3 financial years on CSR activities listed in Schedule VII of the Act. A CSR Committee of the board must be constituted (with at least one independent director for listed companies), a CSR policy prepared and published, and an annual CSR report annexed to the Board's Report.

What is Form SH-4 — and when does a Public Limited Company need to use it?

SH-4 is the Share Transfer Deed — the instrument through which shares in a company are transferred from one person to another. For a Public Limited Company, shares are freely transferable and SH-4 must be executed and delivered to the company within 60 days of the date of execution. The company must register the transfer within 30 days of receipt (Section 56). Stamp duty at 0.015% of the consideration (or market value, whichever is higher) must be paid on the SH-4, as prescribed under the Indian Stamp Act 1899 as amended by the Finance Act 2019 (effective July 1, 2020). The old rate of 0.25% was replaced by the current 0.015% rate under the consolidated stamp duty framework for transfer of securities. For listed companies, shares held in demat form are transferred electronically through the depository (NSDL or CDSL) without a physical SH-4.

Practitioner notePre-IPO share transfers between promoters, between promoter and investor, or between promoter and departing co-founder must be carefully documented at the time of transfer — not reconstructed later. SEBI's DRHP review scrutinises every share transfer in the 3 years preceding the IPO. Transfers without valid SH-4, without proper stamp duty, or at values inconsistent with contemporaneous valuations are frequently questioned.
How is a Public Limited Company wound up — what are the options?

A Public Limited Company can be wound up by: (1) voluntary liquidation under the Insolvency and Bankruptcy Code 2016 (IBC), where the company must be solvent and shareholders pass a special resolution, followed by appointment of an insolvency professional as liquidator; (2) insolvency proceedings under IBC initiated by a creditor, operational creditor, or the company itself; or (3) striking off by the RoC under Section 248 (only for dormant companies that have not commenced business or are not carrying on any business for 2 consecutive years). For listed companies, delisting from the stock exchange (under SEBI Delisting Regulations 2021) must precede any winding-up process.

Practitioner noteWinding up a Public Limited Company — especially a listed one — is significantly more complex and time-consuming than winding up a Private Limited Company or LLP. The cost and timeline of voluntary liquidation under the IBC, including insolvency professional fees and the liquidation process itself, should be factored into the structure decision if there is any possibility the business may not succeed.
Can a Private Limited Company raise money through an IPO?

No. To offer shares to the general public via an IPO, the company must first be converted into a Public Limited Company. The conversion requires a special resolution of shareholders, amendment to MOA and AOA, name change, and RoC filing. Only after the conversion is complete — evidenced by a new Certificate of Incorporation from the RoC — can the company proceed with SEBI DRHP filing and the IPO process. Planning your conversion timeline is critical: SEBI requires 3 years of audited financial statements from the company in its final form, and if the conversion happens mid-way, the restated financial statements for pre-conversion periods must reflect the company as if it were public during those periods.

Practitioner noteWe recommend companies targeting an IPO within 3 years to convert to Public Limited form before the end of the first financial year in which the IPO decision is made — so that the 3-year audited history required by SEBI is available in public company form.
What taxes does a Public Limited Company pay?

A domestic Public Limited Company is taxed on its net profit at the corporate tax rate. Under Section 115BAA of the Income Tax Act (optional concessional regime), the effective rate is approximately 25.17% (22% base rate + 10% surcharge + 4% health and education cess), provided the company forgoes certain deductions. Companies that have not opted for 115BAA pay tax at 30% plus applicable surcharge and cess — effective rate around 34.94% for companies with taxable income above ₹10 crore. In addition to income tax: GST on applicable supplies, TDS on all applicable payments, advance tax in 4 instalments, and Dividend Distribution Tax has been abolished — dividends are now taxed in the hands of shareholders.

Practitioner noteListed companies also face Securities Transaction Tax (STT) on transactions in listed securities. For companies paying dividends, withholding tax (TDS under Section 194 or Section 196D for FII shareholders) must be deducted before distribution. India-UAE DTAA provides reduced withholding rates on dividends paid to UAE residents — relevant for promoters who hold shares through UAE holding structures.
What is the timeline to receive the Certificate of Incorporation (COI) for a Public Limited Company?

After all documents are prepared and submitted via SPICe+, the Certificate of Incorporation is typically issued by the Registrar of Companies within 15–20 working days, subject to MCA processing time and the absence of queries. Queries from the RoC — which arise in approximately 20–30% of filings — can add 5–15 additional working days depending on the nature of the query and the response turnaround. PNPC pre-screens all documents before submission to minimise query probability and responds to any queries on the same day they are received.

Practitioner noteDifferent RoC offices (Chennai, Bangalore, Hyderabad, Mumbai) have somewhat different processing patterns and query tendencies. Having incorporated hundreds of companies across all these offices, PNPC has a clear picture of what each office routinely queries — and we address those points in our pre-filing review.
What is a Demat account — and why does a listed Public Limited Company need to maintain shares in demat form?

A Demat account (short for dematerialised account) holds securities in electronic form, eliminating physical share certificates. For listed companies in India, all shares must be held in demat form — physical certificates are not tradable on stock exchanges. The company must sign an agreement with a depository (NSDL or CDSL) and appoint a Registrar and Share Transfer Agent (RTA). From a SEBI directive applicable since 2018, even unlisted public companies are required to issue shares only in demat form for securities offered after the relevant date. Transfer of physical shares was also restricted in 2019.

Practitioner notePre-listing companies often have a mix of physical share certificates (issued in the early days) and later demat-held shares. Dematerialisation of all physical shares before the DRHP filing is typically required — this involves obtaining ISINs from the depository, getting shareholders to open demat accounts, and running a formal demat conversion process that can take several months.
What is the process for issuing ESOPs in a Public Limited Company?

Employee Stock Option Plans (ESOPs) in a Public Limited Company are governed by Section 62(1)(b) of the Companies Act 2013 and the rules thereunder. An ESOP scheme must be approved by a special resolution of shareholders. For listed companies, SEBI (Share Based Employee Benefits and Sweat Equity) Regulations 2021 apply. Key provisions: the exercise price must be determined at the time of grant, the vesting period must be at least 1 year, and the number of options granted under all schemes cannot exceed the limits prescribed by the board/shareholders. The company's CS/company secretary or a PNPC team member handles the quarterly and annual disclosures to the stock exchange for listed company ESOPs.

Practitioner noteUnlisted public companies issuing ESOPs must comply with the Companies Act ESOP rules, which are simpler than SEBI's, but must ensure the scheme is correctly documented before any grants are made. ESOPs granted before the scheme is approved by shareholders can be challenged as invalid. We set up ESOP schemes before the first grant — not after employees begin expecting exercise.
How does India-UAE Double Taxation Avoidance Agreement (DTAA) affect a Public Limited Company with UAE shareholders or operations?

The India-UAE DTAA provides: reduced withholding tax on dividends paid to UAE residents (rates to be confirmed per Treaty; treaty provides for beneficial rates compared to domestic withholding rates); protection against double taxation of business profits; provisions on permanent establishment that determine where business profits are taxed. For a Public Limited Company owned partly by UAE-based promoters or investors, dividends declared by the Indian company to UAE shareholders may benefit from reduced withholding tax under the DTAA, subject to the shareholder holding a Tax Residency Certificate (TRC) from the UAE Federal Tax Authority.

Practitioner noteThe interaction between DTAA benefits, India's General Anti-Avoidance Rules (GAAR) applicable from April 2017, and the Principal Purpose Test (PPT) in new generation treaties requires careful analysis when a UAE entity holds shares in an Indian Public Limited Company. PNPC's India-UAE team advises on this as a unified engagement — not split between separate firms.
What is transfer pricing — and when does it become relevant for a Public Limited Company?

Transfer pricing rules under Sections 92–92F of the Income Tax Act apply when a company engages in 'international transactions' with associated enterprises — typically, related parties in other countries. If a Public Limited Company has a subsidiary abroad, a parent company abroad, or any related-party transactions with non-Indian entities (services, goods, loans, royalties, guarantees), transfer pricing documentation must be maintained and an accountant's report in Form 3CEB must be filed alongside the income tax return. Transactions must be priced at arm's length, supported by a Transfer Pricing Study prepared each year.

Practitioner noteDomestic transfer pricing provisions under Section 92BA also apply to specified domestic transactions above the threshold — these include transactions between associated domestic entities, such as an Indian Public Limited Company and its Indian group companies. PNPC prepares transfer pricing studies and 3CEB certifications for clients with both international and domestic transfer pricing exposure.
What is the cost of incorporating a Public Limited Company — and what does PNPC charge?

Government fees at incorporation depend on the authorised share capital stated in the MOA — there is a fee slab structure under the Companies (Registration Offices and Fees) Rules 2014 that increases with authorised capital. For small public companies with modest authorised capital, government fees are in the range of a few thousand rupees; for larger authorised capital they are higher. State stamp duty on the MOA and AOA subscriber sheets varies by state. PNPC charges a fixed, agreed professional fee for the end-to-end incorporation package — from pre-incorporation consultation through post-incorporation setup. The fee is confirmed in writing before any work begins.

Practitioner noteGovernment fees and stamp duty are not within PNPC's control and are passed through at actuals. PNPC's professional fee covers the CA's time — consultation, document drafting, filing, follow-up, and post-incorporation setup. We do not itemise per query or per revision within the agreed scope. Ask us for a written fee letter before engagement.
My company is already incorporated as a Private Limited Company. Can we raise money from the public without converting?

No. A Private Limited Company is legally prohibited from inviting the public to subscribe to its shares or debentures and from making any public offer. Any such offer would be void and the company and its directors would be in violation of Sections 23 and 42 of the Companies Act 2013. To raise money from the public — via a prospectus or IPO — you must first convert to a Public Limited Company and then comply with SEBI (ICDR) Regulations. Private placements to a closed group of investors (maximum 200 in a rolling 12-month period) are permitted for Private Limited Companies but are not 'public' offers and are governed by Section 42.

Does incorporating as a Public Limited Company impose any immediate listing obligation?

No. Incorporation as a Public Limited Company does not obligate the company to list on any stock exchange. Many Indian companies operate as unlisted Public Limited Companies for years — or indefinitely. The decision to list is entirely separate from the decision to be a public company. Listing is initiated by the company on a voluntary basis by engaging a merchant banker (SEBI registered), preparing a DRHP, and filing with SEBI under SEBI (ICDR) Regulations 2018. The only legal obligation that arises from being a Public Limited Company is the compliance framework under the Companies Act 2013 — not a listing obligation.

What does PNPC's Public Limited Company incorporation package include?

Pre-incorporation advisory consultation — structure decision, name, MOA objects, governance design, NRI/FDI considerations. MCA, trademark, and listed company name clearance check. Custom Memorandum of Association drafted by a senior CA. Custom Articles of Association with public company-appropriate governance provisions. DSC coordination for all 3+ directors including NRI and foreign directors. Complete SPICe+ filing — preparation, review, submission, and query management until COI is issued. PAN and TAN activation tracking. Bank account opening document preparation. ADT-1 (auditor appointment) within 30 days. INC-20A tracking, coordination across all subscribers, and filing within the 180-day window. First Board Meeting agenda and minutes template. Annual compliance calendar for the first financial year. Direct CA contact by phone and WhatsApp. For IPO-track clients: pre-listing cap table audit, financial statement review, and SEBI engagement support are available as additional retained engagements.

Practitioner noteEverything in the incorporation package is at the agreed fixed fee. No surprise charges for MCA query responses, document revisions, or follow-up calls within scope.
Why should an IPO-bound company engage PNPC rather than a portal or a general CA firm?

IPO preparation requires a CA firm that has seen the full lifecycle of a public company — from incorporation through the SEBI DRHP process to post-listing compliance. The financial statements in a DRHP must be prepared, restated, and certified under the direct supervision of the statutory auditor. SEBI observations on financial matters — which are common in the DRHP review — require a CA who can respond with authority, not a junior representative of a large audit firm where the partner is unavailable. PNPC has operated since 1986. Our engagements are partner-led. We are present in both India and the UAE. And we take on a limited number of IPO-track engagements at any given time — precisely so we can give each one the attention it requires.

Practitioner noteWe sometimes have to decline IPO mandates because our capacity is full. We would rather tell a prospective client honestly than take on an engagement we cannot service at the level it requires. If you are planning an IPO, speak to us early — 24 months before your target listing date, not 6.
Can a Public Limited Company accept deposits from the public?

Certain categories of public companies may accept deposits from members of the public under Section 73 and Section 76 of the Companies Act 2013, read with the Companies (Acceptance of Deposits) Rules 2014. Eligibility requires that the company must have a net worth of ₹100 crore or more, or a turnover of ₹500 crore or more, and comply with conditions including credit rating, deposit insurance, and filing of a statement of deposits with the RoC. Deposits accepted in violation of these provisions are illegal — the company and its directors face significant criminal liability. Private Limited Companies generally cannot accept deposits from the public (only from members, directors, and their relatives, subject to conditions).

Practitioner noteThe public deposit route is rarely used by modern companies for fundraising — bond markets and bank credit are generally more accessible and less administratively burdensome. However, for legacy NBFCs and certain financial sector companies, this provision remains relevant.
Why PNPC Global

PNPC vs. online portals for Public Limited Company formation

FeatureOnline PortalPNPC Global
Pre-filing strategyNo advisory — forms filed as receivedDeep CA consultation: is Public Ltd right now, or convert from Pvt Ltd later? Sector analysis, NRI/FDI check, listing-readiness assessment
Name clearanceSingle MCA search onlyMulti-layered: MCA, IP India trademark, listed company names, restricted word check, RoC-specific patterns
MOA draftingStandard template — identical for every clientCustom objects clause — correct for sector, licensing requirements, and future diversification without inviting RoC query
AOA draftingTemplate with private company restrictions retained by errorPublic company-specific AOA — correct quorum, free transfer provisions, governance committees, investor reserved rights where applicable
7-subscriber coordinationForm sent to client, client manages signatoriesPNPC coordinates all 7+ subscriber signatures, bank payment timing, and INC-20A subscription sequence
INC-20A managementNot mentioned; engagement closes at COIProactively tracked from Day 1; initiated at Day 90 of 180-day window across all subscribers
Compliance calendarNot providedProactive calendar — every deadline across MCA, income tax, GST, and TDS, initiated in advance each year
Secretarial complianceNot in scopeBoard meeting minutes, AGM notice and agenda, resolutions, secretarial audit (where required) — all managed by PNPC
Pre-IPO supportNot offeredCap table audit, financial statement review, SEBI engagement support, transfer pricing, FEMA compliance — all from PNPC
NRI / UAE foundersIndia process only; UAE separately to another firmSingle engagement across Chennai/Bangalore/Hyderabad and Dubai — FDI, FEMA, DTAA, and UAE entity — one CA team
When you get a noticeSupport ticket or no responseDirect engagement CA — by phone and WhatsApp — who knows your company and its full history
Business model alignmentRevenue from registration volume; incentive ends at COIRevenue from long-term retained relationships; our incentive is your company's ongoing success and compliance

What the PNPC package includes

  1. 01

    Pre-incorporation advisory consultation — structure decision (Public vs Private vs convert), name strategy, MOA objects, authorised capital, NRI/FDI status assessment

  2. 02

    Multi-source name clearance — MCA, IP India trademark, listed company names, restricted word check

  3. 03

    Custom Memorandum of Association drafted by a senior CA — sector-specific, future-proof objects clause

  4. 04

    Custom Articles of Association — public company quorum, free share transferability, committee provisions, governance architecture appropriate for unlisted or pre-listing stage

  5. 05

    DSC coordination for all 3+ directors — including NRI and foreign directors via Dubai office and apostille coordination

  6. 06

    Complete SPICe+ filing — form preparation, all attachments, submission, and real-time MCA query management until COI issued

  7. 07

    7+ subscriber coordination — signature collection, bank subscription payment sequencing, INC-20A coordination

  8. 08

    INC-20A tracking and filing — initiated proactively at Day 90 of the 180-day post-COI window

  9. 09

    Form ADT-1 (auditor appointment) — filed within the mandatory 30-day window from COI date

  10. 10

    First Board Meeting agenda, resolutions, and minutes template — signed within 30-day statutory window

  11. 11

    Statutory register setup — Register of Members, Directors and KMP, Charges, Related Party Contracts

  12. 12

    Annual compliance calendar for the first full financial year — every MCA, income tax, TDS, and GST due date pre-populated

  13. 13

    PAN, TAN activation tracking and bank account opening document preparation

  14. 14

    Direct CA contact by phone and WhatsApp for post-incorporation questions — your engagement CA, not a support queue

Speak directly with a PNPC Chartered Accountant — not a salesperson, not a chat widget. A practising CA who has navigated every stage of public company life, from incorporation through pre-IPO restructuring, since 1986.

← Back to Business Setup
Talk to a CA