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Microlesson · 5-min read

Registration of Prospectus (Section 389)

# Registration of Prospectus [Section 389]

## Applicability

A prospectus offering securities of a company incorporated outside India (whether or not having place of business in India) in India.

## Conditions for Issue, Circulation, Distribution

The prospectus shall be issued, circulated and distributed only if:

### Part A: Delivery and Disclosure

  • A copy of the prospectus is certified by the chairperson and 2 directors (certifying that the prospectus is approved by the resolution of the managing body) and is delivered to the ROC for registration.
  • The prospectus states on its face that a copy has been delivered to the ROC.

### Part B: Annexures Required

Consent required under Section 388 (Expert Consent) and the following prescribed documents must be annexed:

1. Copy of contract of appointment of MD/Manager (if not in writing — a memorandum with full particulars must be annexed).

2. Copy of other material contracts entered into within the last 2 years, not in the ordinary course of business.

3. Copy of power of attorney (if prospectus is signed by authorised agent of directors).

4. Copy of underwriting agreement.

5. Expert consent to issue of prospectus.

## Summary Checklist for Compliance

StepRequirement
1Prospectus certified by chairperson + 2 directors
2Approval by managing body resolution
3Delivery to ROC for registration
4Face of prospectus mentions ROC delivery
5Expert consent (Section 388) obtained
6Required documents annexed

Worked example

### Example 1

Example: A French company wishes to issue a prospectus in India. It must (1) get the prospectus signed by its chairperson and 2 directors; (2) attach a board resolution approving the prospectus; (3) annex its MD's appointment contract, all material contracts of the last 2 years outside ordinary business, expert consents, etc.; (4) deliver a certified copy to the ROC; and (5) state on the face of the prospectus that ROC delivery has been done.

⚠️ Common exam mistakes

  • Confusing 'material contracts' — only those entered in the last 2 years AND outside the ordinary course of business need to be annexed.
  • Forgetting to mention ROC delivery on the face of the prospectus.
  • Annexing the MD's appointment contract but missing the memorandum of particulars when the contract is oral.
Reference: Section 389 — Companies Act, 2013
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