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Issue of Debentures (S.71)

Issue debentures: Board + SR (if convertible), appoint trustee, create DRR, register charge. Issue of Debentures (S.71) takes 7 steps over about 133 days and is filed with the ROC on CHG-9 and PAS-3.

7 steps~133 days start to finishfiles CHG-9files PAS-3

Last updated: 10 August 2026

What if it’s filed late?

MCA charges additional fees that rise with the delay, up to 12 times the normal filing fee. OnCompliance tracks the date and warns you before it costs anything.

See this deadline for your clients →

What is the timeline for Issue of Debentures (S.71)?

7 steps over about 133 days, filing CHG-9 and PAS-3 with the ROC. Each deadline below runs from the step before it.

#StepForm filedDeadline
1Board Approves Debenture IssueNonewithin 7 days
2Pass SR (if convertible)Nonewithin 30 days
3Appoint Debenture TrusteeNonewithin 14 days
4Create Debenture Redemption ReserveNonewithin 7 days
5Issue DebenturesNonewithin 30 days
6File CHG-9 (Charge for Debentures)CHG-9within 30 days
7File PAS-3PAS-3within 15 days

What are the steps, in order?

The 7 steps below run in order; the day counts show how long each one allows.

1

Board Approves Debenture Issue

Board approves terms of debenture issue.

within 7 days · document made for you
2

Pass SR (if convertible)

SR required for issue of convertible debentures.

within 30 days
3

Appoint Debenture Trustee

Appoint a debenture trustee before issue.

within 14 days
4

Create Debenture Redemption Reserve

Create DRR of at least 10% for listed companies.

within 7 days
5

Issue Debentures

Allot debentures and collect subscription money.

within 30 days · document made for you
6

File CHG-9 (Charge for Debentures)

Register charge on assets for secured debentures.

within 30 days · files CHG-9
7

File PAS-3

File return of allotment within 15 days.

within 15 days · files PAS-3 · document made for you
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Every guide runs like this in OnCompliance: steps in order, dates in view, paperwork made for you at each step.

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Common questions

How long does Issue of Debentures (S.71) take?

About 133 days across 7 steps. The first step is: Board Approves Debenture Issue.

Which MCA forms are filed for Issue of Debentures (S.71)?

CHG-9 and PAS-3. PAS-3 is the return of allotment filing under §39 of the Companies Act 2013.

What does it cost if CHG-9 and PAS-3 are filed late?

MCA charges additional fees that rise with the delay, up to 12 times the normal filing fee.

Can OnCompliance run Issue of Debentures (S.71) for me?

Yes. OnCompliance runs the same steps in order, dates in view, with the paperwork made for you at each step.