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Private Placement (S.42)

Issue shares via private placement: Board + SR, PAS-4 offer letter, max 200 persons per FY. Private Placement (S.42) takes 8 steps over about 209 days and is filed with the ROC on PAS-4, PAS-3, MGT-14 and PAS-5.

8 steps~209 days start to finishfiles PAS-4files PAS-3files MGT-14files PAS-5

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 Private Placement (S.42)?

8 steps over about 209 days, filing PAS-4, PAS-3, MGT-14 and PAS-5 with the ROC. Each deadline below runs from the step before it.

#StepForm filedDeadline
1Pass Board ResolutionNonewithin 7 days
2Pass Special Resolution at GMNonewithin 30 days
3Issue PAS-4 Offer LetterPAS-4within 7 days
4Collect Application MoneyNonewithin 30 days
5Allot SharesNonewithin 60 days
6File PAS-3 with ROCPAS-3within 15 days
7File MGT-14MGT-14within 30 days
8File PAS-5 (Record of PP)PAS-5within 30 days

What are the steps, in order?

The 8 steps below run in order; the day counts show how long each one allows.

1

Pass Board Resolution

Board approves private placement including pricing and terms.

within 7 days · document made for you
2

Pass Special Resolution at GM

Members pass SR for private placement.

within 30 days
3

Issue PAS-4 Offer Letter

Send private placement offer letter (PAS-4) to identified persons. Max 200 per FY per type.

within 7 days · files PAS-4 · document made for you
4

Collect Application Money

Receive application money. Must allot within 60 days or refund.

within 30 days
5

Allot Shares

Board allots shares within 60 days of receipt of application money.

within 60 days · document made for you
6

File PAS-3 with ROC

File return of allotment within 15 days.

within 15 days · files PAS-3 · document made for you
7

File MGT-14

File SR with ROC within 30 days.

within 30 days · files MGT-14
8

File PAS-5 (Record of PP)

Maintain and file record of private placement.

within 30 days · files PAS-5
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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 Private Placement (S.42) take?

About 209 days across 8 steps. The first step is: Pass Board Resolution.

Which MCA forms are filed for Private Placement (S.42)?

PAS-4, PAS-3, MGT-14 and PAS-5. PAS-3 is the return of allotment filing under §39 of the Companies Act 2013. MGT-14 is the filing of resolutions filing under §117 of the Companies Act 2013.

What does it cost if PAS-4, PAS-3, MGT-14 and PAS-5 are filed late?

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

Can OnCompliance run Private Placement (S.42) for me?

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