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Secretarial compliance calendar

BEN-2: return of significant beneficial ownership — workflow

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

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

Define the obligation before assigning the task

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

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

Related guide: Form reference and completed fields

Walk the event through the calendar

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.

1. Establish the event and evidence

Trace the ownership/right chain and applicable exemptions; obtain and check the section 90 declaration.

2. Prepare the correct document

Select the actual purpose, input each qualifying SBO/member chain and preserve acquisition, declaration and receipt dates; attach the declaration.

3. Submit and follow through

File the actual BEN-2 within the receipt-based period, maintain the BEN-3 register and retain the real acknowledgement and chain evidence.

Record the controls and reconcile the outcome

Control to recordWorked scenario
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.

Keep the source and example with the working papers

Official prescribed referenceWorked field example — fictional

This is the same form, version and scenario as the linked detailed reference. The full field table is maintained there; this page concentrates on responsibilities, sequencing and evidence. No sample creates a DSC, professional certification, approval or acknowledgement. It is a static educational illustration with deliberately invalid synthetic identifiers.

Primary authorities and exact locators

Close the task using the actual result

The example assumes the full 2019 SBO legal test was independently established; this field illustration does not replace examining indirect-right, majority-stake and exemption provisions.

Retain the actual submitted or issued version together with the source records described above. If the authority requests a correction or a required approval has not arrived, preserve that status and the response trail; a saved draft is not evidence of completion.