Legal Framework and Compliance Requirements
1
Section 88
mandates the maintenance of the register of members, debenture holders, and other security holders. This section requires companies to maintain separate registers for different classes of shares and provides for authentication requirements. Section 170 specifically deals with the register of directors and key managerial personnel with detailed disclosure requirements.
2
Section 85
covers the register of charges for any mortgages or securities created by the company. Section 189 requires maintenance of register for contracts and arrangements where directors are interested. The Companies (Management and Administration) Rules, 2014 provide detailed formats and procedures for maintaining these registers.
3
The Companies (Significant Beneficial Owners) Rules, 2018
which were notified around that period, introduced the requirement for the SBO register. Provisions for electronic maintenance and authentication are contained within the Companies (Management and Administration) Rules, 2014, and the Information Technology Act, 2000.
The Step-by-Step Process for Maintaining Statutory Registers
Setindiabiz provides comprehensive assistance for maintaining statutory registers with complete legal compliance. Our systematic approach ensures accuracy and timeliness.
1
Step-1: Initial Register Setup (Days 1-3)
Set up all mandatory registers in the formats prescribed by the Companies Act Rules, such as Form MGT-1 for members and Form SH-1 for share certificates. It is crucial to identify all registers applicable to the company. These formats are stipulated in the Rules, not provided directly by the Registrar of Companies.
2
Step-2: Data Collection and Verification (Days 4-7)
Collect all relevant documents and information from company records, directors, and members. Verify the accuracy of personal details, shareholding patterns, and legal documentation. Cross-check information with official records like the PAN database and ensure all details are current and complete before entering into registers.
3
Step-3: Register Entry and Authentication (Days 8-10)
Make entries in all applicable registers within seven days of board approval for allotments or transfers. Ensure proper authentication by company secretary or authorized person as mandated by rules. All entries must be dated and signed appropriately to maintain legal validity and avoid future complications.
4
Step-4: Record of Decisions (Continuous)
The decisions leading to entries (e.g., share allotment, transfer) must be recorded in board minutes. The register entries must then be authenticated by the Company Secretary or another person authorised by the Board. This authentication does not need to occur at a board meeting, but must be completed promptly after the entry is made.
5
Step-5: Ongoing Maintenance and Updates (Continuous)
Update registers within prescribed timelines for any changes in membership, directorship, or other relevant information. Maintain registers at the registered office and ensure availability for inspection by authorised persons. File necessary forms with the Registrar of Companies when required and keep backup copies for security.