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Microlesson · 5-min read

Conditions for Acceptance of Deposits by Eligible Public Companies (Credit Rating, Circular, Secured Deposits)

# Conditions for Eligible Public Companies Inviting Public Deposits

An eligible public company must satisfy several procedural conditions before inviting deposits from persons other than members.

## 1. Credit Rating Requirement

  • Must obtain a credit rating from a recognised credit rating agency specified for NBFCs, indicating adequate safety for repayment.
  • The rating must be disclosed to the public at the time of invitation.
  • Rating must be obtained every year during the tenure of the deposit.
  • A copy of the credit rating must be filed with the ROC along with the Return of Deposits in Form DPT-3.
  • The rating shall not be below the minimum investment grade rating specified for fixed deposits.

## 2. Issuance of Circular (Form DPT-1)

  • A circular must be issued in the form of an advertisement in Form DPT-1.
  • Advertisement is to be published in:
  • One English newspaper, and
  • One vernacular language newspaper having wide circulation in the State where the registered office is situated.
  • It must also be placed on the company's website.
  • Date of issue = the date the advertisement appears in the newspaper.
  • At least 30 days before issue of advertisement, a copy of the circular signed by a majority of directors (or their authorised agent) must be filed with the ROC for registration.
  • The circular must be authorised by the Board and remains valid till the earlier of:
  • 6 months from the closure of the FY in which it was issued, or
  • The date on which the financial statements are laid in the AGM (if no AGM held, the last day by which AGM should have been held).
  • After expiry, a fresh advertisement is required for further invitations in that FY.

## 3. Security for Secured Deposits

If the company accepts secured deposits from the public, it must:

  • Create a charge on its tangible assets (specific movable/immovable property) within 30 days of acceptance.
  • The company cannot create charge on intangible assets.
  • The value of security cannot be less than the amount of deposit + interest.
  • Charge must be created in favour of a trustee for depositors.
  • Market value of the secured assets must be assessed by a registered valuer.

## 4. Disclosure in Financial Statements

A public company must disclose money received from its directors in its financial statements.

## Key Definitions and Limits

### Net Worth

= Paid-up share capital + All reserves created out of profits + Securities premium

Less: Accumulated losses + Deferred expenditure + Miscellaneous expenditure not written off.

Excludes: Revaluation reserves, write-back of depreciation reserves, and amalgamation reserves.

### Borrowing Limit u/s 180(1)(c)

Money to be borrowed + Already borrowed ≤ Paid-up share capital + Free reserves + Securities premium.

Borrowings here exclude temporary loans — loans repayable on demand or within 6 months (e.g., cash credit), not raised for capital expenditure, obtained from a bank in the ordinary course.

## Maximum Deposit Limits — Quick Summary

Type of CompanyFrom MembersFrom Public
Private Company (general)100% of (PUSC + FR + SP)Not allowed
Private Company — Start-up (10 yrs) / Satisfies 3 conditionsNo limitNot allowed
Public Company (not eligible)35% of (PUSC + FR + SP)Not allowed
Eligible Public Company10% of (PUSC + FR + SP)25% of (PUSC + FR + SP)

## Deposit Tenure

  • Less than 3 months: Not permitted.
  • 3 to 6 months (short-term): Permitted up to 10% of (PUSC + FR + SP).
  • 6 to 36 months: Permitted within applicable overall limits.
  • Premature repayment is permitted, but the interest rate is reduced by 1% below the rate applicable to the period the deposit has actually run.

Worked example

### Example 1

Example — Validity of Circular

ABC Ltd. (an eligible public company) publishes a deposit advertisement in DPT-1 on 1st May 2025 (FY 2025-26). Its AGM for FY 2025-26 is held on 15th August 2026.

Validity expires on the earlier of:

  • 6 months from end of FY 2025-26 = 30th September 2026, OR
  • Date of AGM = 15th August 2026.

→ The circular is valid only till 15th August 2026. To continue accepting deposits thereafter, a fresh advertisement must be issued.

### Example 2

Example — Maximum Deposit Limit

XYZ Ltd. (eligible public company) has: Paid-up share capital ₹50 cr, Free reserves ₹30 cr, Securities premium ₹20 cr → Base = ₹100 cr.

  • From members: max 10% × 100 = ₹10 crore.
  • From public (non-members): max 25% × 100 = ₹25 crore.

Total possible deposits = ₹35 crore.

### Example 3

Example — Punishment u/s 76A

PQR Ltd. accepts ₹3 crore in deposits in violation of Section 73 and fails to repay.

  • Company fine: not less than the lower of ₹1 crore or 2 × ₹3 cr = ₹6 cr, so minimum ₹1 crore; maximum extends up to ₹10 crore.
  • Officer in default: imprisonment up to 7 years + fine ₹25 lakh to ₹2 crore.
  • If the officer acted knowingly/wilfully to deceive — liable under Section 447 (fraud).

⚠️ Common exam mistakes

  • Confusing net worth with paid-up capital — net worth includes free reserves & securities premium net of accumulated losses.
  • Forgetting that revaluation reserves and amalgamation reserves are excluded from net worth.
  • Treating credit rating as a one-time requirement — it must be obtained every year during the tenure of the deposit.
  • Believing security can be created on intangible assets — only tangible assets (movable/immovable) qualify.
  • Mistaking the validity period of the circular — it is the earlier of 6 months from FY end OR AGM date, not the later.
  • Forgetting that a temporary loan from a bank (≤ 6 months, not for capex) is excluded from borrowings while computing Section 180(1)(c) limits.
  • Confusing the punishment limits under Section 76A — the lower of ₹1 cr or twice the deposit is the minimum, not the maximum.
Bare-Act text Section 76A · Companies Act, 2013 · click to expand
Section 76A — Punishment for Contravention of Section 73 or Section 76: Where a company accepts or invites or allows or causes any other person to accept or invite on its behalf any deposit in contravention of the provisions of Section 73 or 76 or fails to repay the deposit or part thereof or any interest thereon within the time specified or such further time as may be allowed by the Tribunal, the company shall, in addition to repayment of the amount of deposit and interest due, be punishable with fine which shall not be less than one crore rupees or twice the amount of deposit accepted by the company, whichever is lower, but which may extend to ten crore rupees; and every officer of the company who is in default shall be punishable with imprisonment which may extend to seven years and with fine not less than twenty-five lakh rupees but which may extend to two crore rupees. If it is proved that the officer of the company who is in default has contravened such provisions knowingly or wilfully with the intention to deceive the company or its shareholders or depositors or creditors or tax authorities, he shall be liable for action under section 447.
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