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Compliance

Statutory Registers

Statutory Registers are official records maintained by companies as required by the Companies Act, including member register, director register, and charge register.

Key Points

Mandatory books under Companies Act
Must be kept at registered office
Open for member inspection
Can be maintained electronically
Penalties for non-maintenance

Every company incorporated in India must maintain a defined set of statutory registers — the formal books of record mandated by the Companies Act, 2013. Kept at the registered office and updated as events occur, these registers evidence a company's ownership, management, borrowings and related-party dealings. They are usually the first documents a Registrar of Companies (ROC) inspector, statutory auditor or due-diligence team asks to see.

What statutory registers are

Statutory registers are separate from your accounting books and minute books. They record the company's legal structure and key transactions in a prescribed format. Most are governed by specific sections of the Companies Act, 2013 read with the relevant rules, and several use MCA-notified forms. Failing to maintain them accurately is a standalone offence, independent of whether your accounts are otherwise in order.

Registers every company must keep

The core registers, with their governing provisions and prescribed forms, are:

RegisterFormProvision
Register of MembersMGT-1Section 88
Register of Debenture-holders / other security holdersMGT-2Section 88
Register of Directors and KMP and their shareholdingSection 170
Register of ChargesCHG-7Section 85
Register of Loans, Guarantee, Security and InvestmentsMBP-2Section 186
Register of Contracts with interested directorsMBP-4Section 189
Register of Renewed and Duplicate Share CertificatesSH-2Share Capital Rules

Note that Form MBP-4 belongs to the Register of Contracts (Section 189), not the Register of Directors — a common labelling error. Registers for debenture-holders, sweat equity, ESOP or buy-back apply only when the relevant event has actually occurred.

How they must be maintained

  • Location: at the registered office. Under Section 94, they may be kept elsewhere in India where more than one-tenth of members reside, if approved by special resolution and a copy is filed with the ROC.
  • Electronic form: registers may be maintained electronically under Section 120; records must be legible, tamper-evident and retrievable.
  • Preservation: the Register of Members and Register of Charges are preserved permanently; other registers are retained for the periods specified in the rules.
  • Inspection: under Section 94, members and debenture-holders may inspect key registers free of charge during business hours; any other person may inspect on payment of the prescribed fee.
  • Authentication: entries must be made promptly, in chronological order, and authenticated by the company secretary or a person authorised by the Board.

Penalties for non-maintenance

The consequences are real and increasingly enforced. For the Register of Members, debenture-holders or other security holders, Section 88(5) imposes a penalty of ₹3 lakh on the company and ₹50,000 on every officer in default. Other registers carry their own penalties, and the MCA has issued a growing number of adjudication orders — including for a missing Form MBP-4 — so treat these as live compliance items, not mere paperwork.

Practical tips

  • Update each register at the time of the event (allotment, transfer, charge creation, board appointment), not once a year before the AGM.
  • Reconcile the Register of Members and Register of Directors with your MCA filings (MGT-7/7A, DIR-12) so the records never diverge.
  • If you outsource secretarial work, confirm your company secretary holds the physical or electronic registers and keeps them current.
  • Keep the registers ready for inspection — investors and lenders routinely demand them during due diligence.

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