INC-20A
What INC-20A means, how it works, a worked example, the mistakes we see and the questions founders ask.
DefinitionINC-20A is the declaration of commencement of business a company must file within 180 days of incorporation, confirming the shareholders have paid for their shares and the registered office is verified.
A company incorporated after November 2018 cannot start business or borrow until it files INC-20A. The form attaches the bank statement showing each subscriber deposited their share money, proof of the registered office, and any sector regulator approval needed, and a director signs it with a DSC. The deadline is 180 days from the date on the Certificate of Incorporation. You meet it in your first six months, usually right after opening the bank account. What it means for you: miss it and the penalty is ₹50,000 on the company and ₹1,000 per day on each officer up to ₹1 lakh, and the Registrar can strike the company off. Banks and investors check the filing during diligence, so a late INC-20A raises questions. Deposit the capital early and file in the first month.
How INC-20A works
Since the Companies (Amendment) Ordinance of 2018, a company with share capital cannot start business, borrow or exercise any borrowing powers until its directors declare that every subscriber to the memorandum has paid for their shares. INC-20A is that declaration. It is filed within 180 days of incorporation, signed by a director and certified by a practising professional.
The attachment that matters is the bank statement or other proof showing the subscription money credited to the company's account; for a company with a foreign shareholder the FIRC and the FC-GPR reporting go alongside. If the registered office was not verified at incorporation, INC-22 must be filed first, because INC-20A asks for that verification too.
The consequences of missing it are severe for a form that takes an afternoon. The company is liable to a ₹50,000 penalty and each defaulting officer to ₹1,000 per day up to ₹1 lakh, and after 180 days the Registrar may strike the company off the register on the footing that it never began business.
Two founders incorporate a Delhi company on 5 January with ₹1 lakh capital, ₹50,000 each. They open the current account in February and each transfers ₹50,000 on 3 March. The INC-20A is filed on 10 March with the bank statement showing both credits, 64 days after incorporation and well inside the 180-day limit of 4 July. Only now can the company sign its first customer contract and take a bank overdraft.
Mistakes we see with INC-20A
- Paying the subscription money in cash or from a third party's account, so the bank statement does not evidence each subscriber's payment.
- Opening the bank account late and running out of the 180 days, then discovering the account opening itself needed the certificate of incorporation the bank wanted weeks for.
- Starting to invoice customers before the declaration is filed, which is itself a contravention of Section 10A.
Last updated 19 October 2026. Checked against the MCA, GST, Income-tax and Trade Marks rules in force for October 2026.
Where you will meet this term
- Private Limited CompanyFounders who plan to raise money or hirefrom ₹4,999
- Company Annual FilingsPrivate Limited Companies, OPCs and LLPs that want every ROC filing done on time, with the AGM and audit coordinated.from ₹9,999/year
- One Person CompanyFor a solo founder who wants limited liability and a company name without a co-founder.from ₹4,999
Questions founders ask about INC-20A
What is the time limit for INC-20A?
180 days from the date of incorporation. There is no extension; a late filing carries the additional fee and the penalties under Section 10A, and leaves the company exposed to strike-off.
Does a company without share capital file INC-20A?
No. The declaration applies to companies incorporated with share capital after 2 November 2018. A company limited by guarantee without share capital is outside it.
Can we take a loan before filing INC-20A?
No. Until the declaration is filed the company cannot commence business or exercise any borrowing powers, so a loan, an overdraft and even a director's loan should wait.