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Companies Act · source-checked form guide

BEN-2: return of significant beneficial ownership

Sources checked 21 October 2026 · Original author: CA Nikhil Gupta

The reporting company returns declarations under section 90; it must trace the qualifying individual and actual holding/right rather than just list registered shareholders.

Which version and who acts?

Current MCA webform workflow and field definitions in the retrieved official instruction kit; actual portal schema controls submission.

Reporting company authorised signatory; the individual’s BEN-1 declaration and company’s BEN-3 register are distinct records.

MCA BEN-2 instruction kit, physical PDF pp6–15 field instructions and p18 receipt-based 30-day period.

Completed field illustration

Fictional example — not for filing. The fictional company receives a BEN-1 on 5 October 2026 from Mira Example. She wholly owns Example Holding Private Limited, which holds 20% of the reporting company’s voting shares. The reporting company has verified the chain; it prepares the return on 21 October.

Prescribed field / blockCompleted fictional entry
1–2 Reporting companySYNTHETIC-CIN-01; deliberately not a valid CIN; Aurelia Demonstration Private Limited (fictional)
3 PurposeFor declaration of Significant Beneficial Ownership under Section 90.
5(a) SBOs / member chains1 SBO; 1 corporate member through which the right is exercised.
6A Nature / percentageIndirect share/voting holding through the corporate member; 20% in reporting company.
6B Registered memberExample Holding Private Limited (fictional); entered in section 88 register on 01/10/2026.
6C Indirect interest / chainMira owns 100% of the corporate member; member owns 20% of reporting company.
6D Identity / acquisition / declaration / receiptMira Example, Indian resident, synthetic identity marker; 01/10/2026 / 04/10/2026 / 05/10/2026.
6D Direct holdingNo direct holding in reporting company.
Attachment / declarationBEN-1 declaration; Board authorisation assumed 20/10/2026. Not signed. No DSC, certification, SRN, filing or approval has occurred.

The named fields illustrate this scenario. The official reference contains the additional applicable fields, schedules, attachments and declarations. Synthetic identifiers are not valid input for a live filing. No signature, certification, authority action or successful filing is represented.

Check the dates, amounts and legal branch

Prepare, submit and retain the evidence

  1. Trace the ownership/right chain and applicable exemptions; obtain and check the section 90 declaration.
  2. Select the actual purpose, input each qualifying SBO/member chain and preserve acquisition, declaration and receipt dates; attach the declaration.
  3. File the actual BEN-2 within the receipt-based period, maintain the BEN-3 register and retain the real acknowledgement and chain evidence.

Download the right reference and sample

Official prescribed referenceFilled sample: fictional field illustration

The reference preserves the complete official source document. Use the physical PDF page locators above to find this form; adjacent forms and amendment provisions may share a page. The sample is a static educational model, not an MCA utility, statutory approval or executed filing.

Related guide: Secretarial filing workflow

Primary authorities and exact locators

Questions readers ask

What does this PDF complete?

It illustrates the named prescribed fields with fictional facts. The real statutory document must include every applicable field and annexure, supported by actual records and authorised verification.

Does downloading the sample create a filing or approval?

No. Follow the specific preparation and submission steps above. The actual portal acknowledgement, authority decision or signed professional report is separate evidence.

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