Rule 1Short title and commencement
Companies (Registration of Charges) Rules, 2014; effective from 1 April 2014.
Registration of Charges,
Satisfaction and Rectification
A professional rulebook on sections 77-87, charge classification, creation and modification, lender-led filing, charged-property acquisition, satisfaction, receiver notices, CHG-7, rectification, insolvency signatures and cross-law perfection.
13 Rules
Rules 1-13
Rules 1-13
30/60/120 Days
Creation and modification
Creation and modification
30/300 Days
Satisfaction
Satisfaction
Permanent CHG-7
Security record
Security record
Executive architecture
Four questions determine whether security is protected
Was security created?
Identify a proprietary interest or lien over company property.
Was it filed in time?
Apply the current creation/modification or satisfaction clock.
Was it perfected elsewhere?
Stamp, property, CERSAI and sector systems remain separate.
Is the record current?
Track modifications, enforcement, satisfaction and CHG-7.
Priority risk: an unregistered charge may be ignored against the liquidator and creditors even though the underlying debt survives.
Lifecycle
Charge and CHG form map
Act gateway
Sections 77-87 working register
| Section | Subject | Control |
|---|---|---|
| 77 | Duty to register charges | Register every charge on property, assets or undertakings, whether tangible, intangible, in or outside India. |
| 78 | Charge-holder filing | Lender may file after company misses first 30 days; Registrar gives notice. |
| 79 | Modification | Section 77 applies to modification and property acquired subject to charge. |
| 80 | Constructive notice | Registration gives notice from date of registration. |
| 81 | Registrar's register | Public charge record maintained by Registrar. |
| 82-83 | Satisfaction and Registrar action | Company reports full satisfaction; Registrar may act on evidence after notice. |
| 84 | Receiver/manager | Appointment and cessation notified. |
| 85-86 | Company register and penalties | Permanent internal record and statutory consequences. |
| 87 | Rectification/extension | Central Government/Regional Director route for eligible omission, misstatement or delayed satisfaction. |
Current rules
Companies (Registration of Charges) Rules
Rule 2Definitions
Defines Act, form/e-form, fees, Regional Director and section.
Rule 3Registration of creation or modification
CHG-1 for charges other than debenture charges and CHG-9 for debenture charges, with certified instrument particulars and prescribed signatures.
Rule 4Particulars of modification
Use the existing charge identity and clearly state the altered amount, property, ranking, terms or operation.
Rule 5Charge-holder filing
Where the company defaults, the charge-holder may file under section 78; the Registrar gives the company notice and can recover fees from it.
Rule 6Certificate of registration
CHG-2 evidences creation and CHG-3 modification; preserve and reconcile with loan/security records.
Rule 7Acquisition of property subject to charge
Register a charge affecting property acquired by the company even though the company did not create the original security.
Rule 8Satisfaction of charge
CHG-4 for full satisfaction; Registrar may issue notice and record satisfaction in CHG-5. Filing up to 300 days follows the delayed-fee route.
Rule 9Receiver or manager
CHG-6 within 30 days of appointment or cessation by the appointing person.
Rule 10Register of charges
Maintain CHG-7 permanently at registered office; authenticate entries and allow statutory inspection.
Rule 11Inspection
Members and creditors inspect without fee; others on payment of prescribed fee, subject to reasonable restrictions.
Rule 12Rectification and extension
CHG-8 for section 87 cases including satisfaction after 300 days and eligible omission/misstatement rectification; not a universal post-120-day creation cure.
Rule 13CIRP and liquidation signature
IRP, RP or liquidator signs CHG-1, CHG-4, CHG-8 and CHG-9 during the insolvency process.
Deadline map
Creation, satisfaction, priority and other-law perfection
Creation and modification
30/60/120-day control matrix
| Period | Route | Professional action |
|---|---|---|
| 0-30 days | Normal CHG-1/CHG-9 filing | Attach executed instrument and complete digital signatures. |
| 31-60 days | Additional fee | File immediately; do not wait for final window. |
| 61-120 days | Further 60 days with ad valorem fee | Use current portal route and preserve delay explanation. |
| After 120 days | Ordinary post-2018 route closed | Do not assume CHG-8 cures the creation delay; obtain transaction-specific legal advice and restructure/recreate only if legally valid. |
Historical trap: the old 300-day creation framework is not the deadline for a new post-2 November 2018 charge.
What is a charge?
Classification principles
| Instrument | Likely treatment | Key question |
|---|---|---|
| Mortgage / hypothecation | Charge | What property and ranking are secured? |
| Pledge | Charge where created by company over its property | Possession, asset identity and depository/perfection. |
| Assignment of receivables | Fact-specific charge/security assignment | Absolute sale or security assignment? |
| Floating charge | Charge | Assets, crystallisation and ranking. |
| Guarantee alone | Not itself a charge | Is any proprietary security also created? |
| Negative lien | Fact-specific | Does it create a proprietary interest or only contractual restriction? |
Modification controls
Events commonly missed
- Increase or reduction in secured facility.
- Addition, substitution or release of collateral.
- Change in ranking, pari passu/inter-creditor terms or trustee.
- Extension of security to new obligations or instruments.
- Amendment changing the extent or operation of the charge.
- Acquisition of property already subject to a charge.
Example: A bank increases a working-capital limit without changing the hypothecation deed title. The secured amount and operation have changed, so modification must be tested and normally filed.
Satisfaction and partial release
30/300-day route
| Event | Form / route | Control |
|---|---|---|
| Full satisfaction within 30 days | CHG-4 | Lender confirmation and zero-balance/security-release evidence. |
| Full satisfaction within 300 days | CHG-4 with additional fee | Current portal delayed route. |
| After 300 days | CHG-8 section 87 extension, then CHG-4 | Explain omission and absence of prejudice. |
| Partial release / restructuring | Usually modification or section 83 evidence route | Do not use CHG-4 unless the registered charge is fully satisfied. |
Forms and records
Primary filing matrix
| Form | Purpose |
|---|---|
| CHG-1 | Creation/modification other than debentures |
| CHG-2 | ROC certificate - creation |
| CHG-3 | ROC certificate - modification |
| CHG-4 | Full satisfaction |
| CHG-5 | ROC satisfaction memorandum/certificate |
| CHG-6 | Receiver/manager appointment or cessation |
| CHG-7 | Permanent company register |
| CHG-8 | Rectification/section 87 extension |
| CHG-9 | Debenture charge creation/modification |
| CHG-10 | Particulars of delay explanation/declaration where built into current process or legacy workflow |
Current portal caution: webform fields and attachments can change. Apply the operative MCA V3 form and instruction kit on filing date.
Other-law perfection
ROC filing is only one layer
| Layer | Why separate |
|---|---|
| Stamp law | Insufficiently stamped security instrument can be inadmissible or unenforceable. |
| Registration Act / land records | Immovable-property mortgage and title-notice requirements. |
| CERSAI | SARFAESI central security-interest record and priority framework. |
| Depository | Pledge/hypothecation marking over dematerialised securities. |
| IBC | Proof of security interest, priority and insolvency filings. |
| Financial statements | Borrowing, security, charge registration and default disclosures. |
CIRP and liquidation
Who signs and why it matters
Rule 13 places CHG-1, CHG-4, CHG-8 and CHG-9 signature responsibility on the IRP, RP or liquidator for a company under CIRP or liquidation. Suspended directors should not continue signing as if management control were unchanged.
Practical cases
Twelve professional scenarios
1. Day-35 CHG-1: File in the additional-fee window.
2. Day-95 creation: File in the further 60-day ad valorem window.
3. Day-140 creation: Ordinary post-2018 filing route is closed; CHG-8 is not a general cure.
4. Lender files: Section 78 permits charge-holder filing after company default.
5. Property acquired subject to mortgage: Register under section 79/Rule 7.
6. CERSAI only: Companies Act registration remains missing.
7. Liquidation without CHG certificate: Secured priority is at serious risk though debt survives.
8. CHG-4 on day 220: Delayed satisfaction filing remains within 300 days.
9. CHG-4 on day 420: Seek CHG-8 extension first.
10. Receiver appointed: CHG-6 within 30 days.
11. Wrong property number: CHG-8 rectification may be available if inadvertent and non-prejudicial.
12. CIRP modification: IRP/RP signs the applicable form.
Audit checklist
Evidence pack and red flags
Evidence
- Board borrowing/security approval
- Stamped executed instrument
- Valuation/title/CERSAI evidence
- CHG acknowledgement and CHG-2/3/5
- CHG-7 and loan-ledger reconciliation
- Modification and satisfaction calendar
Red flags
- Old 300-day creation window used
- CHG-8 assumed to cure every delay
- Guarantee filed as charge without security
- Modification or acquired charge missed
- Repaid charge left open
- Suspended director signs in CIRP
Finin2min Q&A
Quick answers
Normal creation deadline?
30 days.
30 days.
Maximum ordinary post-2018 creation route?
Generally 120 days in total.
Generally 120 days in total.
Can lender file?
Yes, under section 78 after company default.
Yes, under section 78 after company default.
When is CHG-4 used?
Full satisfaction.
Full satisfaction.