Compliance After Company Incorporation: The First 180 Days

The certificate of incorporation starts several clocks at once. Within 30 days you hold the first board meeting and appoint the first auditor. Within two months you hand out share certificates. Within 180 days the shareholders pay in their money and you file Form INC-20A. The first annual general meeting comes within nine months of the first year end.

Why does the first stretch matter so much?

Because the certificate is a beginning, not an end. From the date on the certificate, the company is a legal person with its own duties, and the directors answer for them.

Most of these first steps exist to prove the company is real. Money has actually come in from the shareholders. An auditor is watching the books. The board actually meets. A company that skips them looks like a shell, and the Registrar of Companies (ROC), the officer who keeps the register of companies, treats it that way. Not filing INC-20A is a ground for striking the company off the register.

The timeline at a glance

The CIN is the Corporate Identification Number printed on your certificate. The company's PAN and TAN are printed there too, so you do not apply for them separately.

What happens at the first board meeting?

This is the meeting where the company starts running itself. There is no fixed agenda in the Act, but a typical first meeting covers these, in roughly this order:

1. Note the certificate of incorporation and the memorandum and articles as filed.
2. Take each director's disclosure of interest. Every director tells the board about other companies and firms they are involved in. This is usually done in Form MBP-1.
3. Appoint the first auditor and record the auditor's consent. The auditor holds office until the end of the first AGM.
4. Approve the bank account opened through AGILE-PRO-S and name who can sign.
5. Approve the share certificates for the subscribers, once their money is in.

INC-20A: the filing that decides when you may trade

Many founders think the certificate lets them start selling. Section 10A says otherwise for a company with share capital: it may not commence business or use its borrowing powers until a director files a declaration that every subscriber has paid for the shares they agreed to take.

So the order is fixed. Each subscriber pays the share money into the company's bank account from their own account. Then INC-20A goes in with proof of those payments. The form also asks for a photograph of the registered office, inside and outside, with a director in the frame. More on the office itself in our guide to registered office address proof.

When does your first financial year end?

Usually on the next 31 March. Section 2(41) adds one twist: a company incorporated on or after 1 January may close its first financial year on 31 March of the following year. A company formed on 15 January 2027 could have a first year that runs to 31 March 2028, about 14 and a half months.

That longer year is a company law idea. Income tax still counts its year from 1 April to 31 March, and a new company's first tax year runs from the date it was set up to the next 31 March. Ask your accountant to plan both before you choose.

Taxes start on day one too

A company is a separate taxpayer. If you will sell online, you will need a GST registration for the company. It can be applied for inside AGILE-PRO-S or separately, as our guide to the GST registration process explains. A GSTIN from your old proprietorship does not carry over, because it belongs to a different PAN. And once the company pays rent, contractors or professionals above the limits in the tax law, it has to deduct tax at source (TDS) using its TAN.

A worked example: the first six months

Pooja and Irfan incorporate a company on 1 December 2026 to sell kitchenware online. Authorised capital is Rs 1 lakh, in 10,000 shares of Rs 10. Each subscribes to 5,000 shares, so each owes the company Rs 50,000.

• By 31 December 2026: first board meeting held, first auditor appointed. They gave the registered office in SPICe+, so no INC-22 is needed.
• By the end of January 2027: each pays Rs 50,000 into the company's account and receives a share certificate.
• By 30 May 2027: INC-20A filed. Until then, the company should not trade.
• 31 March 2027: first financial year ends, because they incorporated before 1 January. The first AGM is due by 31 December 2027.

What if they forget INC-20A and file 30 days late? Secondary sources report the section 10A penalty as Rs 50,000 on the company plus Rs 1,000 a day on each officer in default, capped at Rs 1 lakh each. That is Rs 50,000 plus Rs 30,000 for each of the two directors: Rs 1,10,000. More than the company's whole capital, for a form that takes an afternoon.

The mistake people usually make

Thinking "we have not started yet, so nothing is due". The clocks above run from the date of incorporation, not from your first sale. A company that sits idle for six months while the founders finish a product launch can miss the board meeting, the auditor, the share certificates and INC-20A in one go.

The second slip is paying the share money the wrong way: in cash, from a relative's account, or before the company's bank account is active. Pay from each subscriber's own account to the company's account, and keep the bank statement. It is the proof INC-20A depends on.

One more for each director: KYC on your DIN. From 31 March 2026 director KYC is due once in three years, by 30 June, not every year. If you received your DIN with this company, ask your professional which year your first filing falls in. Our note on DSC and DIN for directors has the background.

What comes after the first six months?

A yearly rhythm: board meetings, the audit, the AGM, the financial statements and annual return filed with the ROC, the income tax return, and GST returns every month or quarter. Our annual compliance calendar for a private limited company sets them out date by date.

Frequently asked questions

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