INC-20A Commencement Certificate

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INC-20A mandatory for all companies incorporated post-April 1, 2020. Verifies subscriber payments through bank statement upload within 180 days (extended to 240 days for startups in 2026).

Key Requirements:

  • CS declaration on ₹10 stamp paper
  • Bank statement showing subscription money receipt
  • Proof of business commencement (website, office lease, sales invoice)

2026 Amendments:

  • ESOP allotments require specific declaration
  • Startup exemption extended to DPIIT-recognized companies
  • Form MGT-14 exempt for private companies

Non-compliance Penalties:

  • ₹50,000 per director (fixed)
  • ₹100 per day continuing offence
  • Personal liability on directors

Filing Process:

  1. Login → MCA → INC-20A → Prefill using CIN
  2. Upload bank statement (3 months)
  3. CS declaration → DSC attestation
  4. SRN generation → Payment (₹300 online)
  5. Acknowledgement within 2 days

Practical Tips: File immediately after bank account opening. Use professional bank statements (not passbook). Startups should declare ESOP plans even if unimplemented. MCA launched auto-flagging system identifying incomplete filings.

Essential compliance for all new companies avoiding director disqualification under Section 164(2).

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