Section 89 Beneficial Interest Filing Due Date Checker

Q: Why does Section 89 require separate declarations from registered and beneficial owners?

Because company records only show the registered shareholder, not necessarily who actually holds the beneficial interest — Section 89 disclosure ensures the true ownership/interest structure is captured for transparency and regulatory purposes, not just the name on the register.

Q: What happens after the registered and beneficial owner declarations are filed?

The company itself must then file Form MGT-6 with the Registrar, reporting the beneficial interest disclosed to it — this creates a filed record with the regulator, not just an internal company record.

Beneficial-interest timeline

MGT-4 — registered owner	—
MGT-5 — beneficial owner	—
MGT-6 — company	—

Section 89 and SBO section 90 are separate but can overlap.

How This Is Calculated

When a shareholder registered in a company's records isn't the actual beneficial owner, both the registered owner and the beneficial owner must file declarations (Forms MGT-4 and MGT-5) within a prescribed period from when the beneficial interest arose, and the company must then file its own return (Form MGT-6) within a further prescribed period.

Frequently Asked Questions

Why does Section 89 require separate declarations from registered and beneficial owners? ▼

What happens after the registered and beneficial owner declarations are filed? ▼

Evidence and verification checklist

Confirm the current, in-force text governing Section 89 Beneficial Interest Filing Due Date Checker on the official source linked above - the summary on this page is an implementation aid, not a substitute for it.
Record the exact event/transaction date, since the applicable version of the law, form or threshold can change between the date of the underlying event and today.
Preserve the primary documents (notices, applications, orders, acknowledgements) that would let a reviewer reconstruct how the facts were classified and what was actually done.
Check for a State-specific rule, later amendment or binding judicial decision that may modify how this applies on your facts.

Before relying on this page

This page is a structured implementation summary, not the operative legal text. Portal or process acceptance of a filing does not by itself establish legal compliance - the underlying classification, authority, evidence and timeline still have to be independently correct. Where the facts are contested, high-value, or time-barred if delayed, verify the current position with the official source and, where appropriate, a qualified professional before acting.

Methodology, assumptions and sources

Scope: Checks the filing due dates and applicability of beneficial-interest declarations under Section 89 of the Companies Act, 2013, for shares held in the name of a registered holder on behalf of a beneficial owner.

Calculation logic

Where a person holds shares as a registered holder but the beneficial interest belongs to another person, the beneficial owner must file a declaration (Form MGT-4/MGT-5, per the current form numbering) within 30 days of acquiring the beneficial interest (or of any change in it).

The registered holder (who is not the beneficial owner) must also file a corresponding declaration (Form MGT-4, per current numbering) disclosing the beneficial owner's interest within the same 30-day window.

On receipt of these declarations, the company itself must file a return (Form MGT-6, per current numbering) with the Registrar within 30 days of receiving the declarations, disclosing the beneficial-interest arrangement.

Inputs and assumptions

30-day filing windows for each of the three declarations/returns (beneficial owner, registered holder, company return) follow the current Section 89 provisions and applicable Rules.

This provision applies to any arrangement where the registered holder is not the true beneficial owner (e.g., nominee holdings, trust arrangements) — the checker applies the filing triggers based on the specific holding-structure scenario entered.

Exclusions and edge cases

This Section 89 beneficial-interest filing is distinct from the Section 90 Significant Beneficial Owner (SBO) framework, which has its own, different threshold (10%+ indirect/beneficial ownership or control) and forms (BEN-1/BEN-2) — see the SBO Checker for that separate, threshold-based regime.

Non-compliance carries specific penalty provisions under the Act — this checker addresses the filing-trigger and timeline, not penalty exposure for past non-compliance.

Sources

Review status: reviewed and approved by CA Nikhil Gupta on 18 July 2026.