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Companies Act & MCA

Register of Members Under Section 88: What Private Companies Must Maintain

Register of Members Under Section 88: What Private Companies Must Maintain
Finin2min Compliance Desk·June 2026·7 min readMGT-1

The register of members is the ownership base of the company. If it does not match PAS-3 filings, transfer records, share certificates and annual return data, compliance and investor diligence will fail.

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Section 88 base

Section 88 requires every company to keep and maintain registers including register of members, register of debenture-holders and register of any other security holders in the prescribed form and manner.

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Register update triggers

TriggerUpdate required
Fresh allotmentAdd new member/security holder and holdings.
Share transfer/transmissionUpdate transferor/transferee or legal successor details.
Preference shares/debenturesMaintain class-wise/security-wise register.
Buy-back or redemptionUpdate cancellation/reduction of holding.
Annual return preparationReconcile register with MGT-7/MGT-7A data.
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Control checklist

  • Keep member folio, share class, certificate and distinctive-number details aligned.
  • Update register immediately after board-approved allotment/transfer.
  • Reconcile with share certificates and depository records, if applicable.
  • Preserve old register versions/backups.
  • Use register data as source for annual return.
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Finin2min warning

Cap table software is not statutory register by default. Maintain the register in the legally expected form and evidence trail.
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Build your Companies Act evidence fileKeep approvals, registers, certificates, SRNs, challans and cap table support in one transaction-wise folder.
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Official sources used

This article is intentionally source-limited to official India Code / MCA material. Verify final filing positions with the latest Act, Rules, MCA forms and portal advisories before publishing.

FAQs

Which section covers register of members? â–¾

Section 88 covers register of members, debenture-holders and other security holders.

Should register match annual return? â–¾

Yes. Annual return data should reconcile with statutory registers.

Is cap table enough? â–¾

No. A cap table is useful, but statutory register maintenance remains necessary.

Source and review trail

Use the current official instrument, portal or regulator publication before acting. This panel separates the category authority from page-specific references.

Primary category
Companies Act & MCA
Official starting point
www.mca.gov.in

Page source links

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