Secretarial compliance calendar
BEN-2: return of significant beneficial ownership — workflow
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 record | Worked scenario |
|---|---|
| 6C Indirect interest / chain | Mira owns 100% of the corporate member; member owns 20% of reporting company. |
| 6D Identity / acquisition / declaration / receipt | Mira Example, Indian resident, synthetic identity marker; 01/10/2026 / 04/10/2026 / 05/10/2026. |
| 6D Direct holding | No direct holding in reporting company. |
| Attachment / declaration | BEN-1 declaration; Board authorisation assumed 20/10/2026. Not signed. No DSC, certification, SRN, filing or approval has occurred. |
- Acquisition precedes declaration, which precedes receipt; the return date is 16 days after receipt, within the kit’s 30-day filing period.
- For multiple declarations, the kit uses the earliest receipt to compute the period. Do not date the obligation only from a later Board authorisation.
- 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.
Keep the source and example with the working papers
Official prescribed referenceWorked field example — fictionalThis 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
- MCA BEN-2 instruction kit, physical PDF pp6–15 field instructions and p18 receipt-based 30-day period.
- Companies Act, 2013: the sections expressly identified in the form and explanatory workflow; source copy, read with the specific later rules linked here.
- SBO Rules 2(1)(d),(h), Explanation III(i): majority stake in corporate member and at least 10% qualifying indirect rights.
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.