Launch offer — 25% off with code LAUNCH-25 See plans →
Microlesson · 5-min read

Section 26 - Matters to be Stated in Prospectus

# Section 26 — Matters to be Stated in Prospectus

## Why this matters

A prospectus is the legal document inviting the public to subscribe to securities. Section 26 lays down the core compliance requirements for issuing a prospectus — what must be stated, who must sign, and what timelines apply.

## Key Requirements

### 1. Time Limit for Issue

  • A prospectus must be issued to the public within 90 days of filing with the Registrar of Companies (ROC).
  • Any issue of securities under a prospectus issued beyond 90 days is deemed to be an issue without a prospectus (i.e., illegal issue).

### 2. Main Contents Required

Every prospectus issued by/on behalf of a public company (with reference to its formation or subsequently), or by/on behalf of any person engaged in such formation, shall:

RequirementDescription
(a) Dated & SignedMust be dated and signed
(b) Information & Financial ReportsAs specified by SEBI in consultation with Central Government
(c) Transitional RuleUntil SEBI specifies, existing SEBI Act, 1992 regulations apply
(d) Compliance DeclarationDeclaration that prospectus complies with Companies Act, SCRA 1956, SEBI Act 1992, and rules thereunder

### 3. Exceptions to (a)–(d)

These contents requirements do NOT apply to:

1. Issue to existing members or debenture-holders of a prospectus/application form relating to its shares or debentures.

2. Issue of a prospectus/application form for shares or debentures which are uniform with previously issued shares/debentures that are currently quoted on a recognised stock exchange.

### 4. Statements by Experts — Prohibited Inclusions

A prospectus shall NOT include a statement by an expert if the expert is:

  • (1) Engaged or interested in the formation, promotion, or management of the company; OR
  • (2) Whose written consent has NOT been obtained; OR
  • (3) Whose written consent was obtained but withdrawn before delivery of prospectus to Registrar.

Definition of Expert [Section 2(38)]: includes engineer, valuer, Chartered Accountant, Company Secretary, Cost Accountant, and any other person empowered to issue certificates under any law.

### 5. Mandatory Disclosures on Face of Prospectus

Every prospectus must, on its face:

  • (a) State that a copy has been filed with the Registrar, AND
  • (b) Specify any documents required to be attached, or refer to statements included that specify these documents.

### 6. Punishment for Contravention

  • Company: Fine — Minimum ₹50,000 up to ₹3,00,000.

## Memory Hook

"90-Day Window + Expert Consent + Compliance Declaration" — these are the three pillars of Section 26.

Worked example

### Example 1

Example 1 — 90-Day Rule: XYZ Ltd files prospectus with ROC on 1st January 2026. Company issues prospectus to public on 5th April 2026 (95 days later). Answer: Since the issue is beyond 90 days, the issue of securities is deemed to be without a prospectus — making the issue illegal under Section 26.

### Example 2

Example 2 — Expert Consent Withdrawn: A company includes a valuation report by a registered valuer in its prospectus. The valuer gave written consent on 10th March but withdrew it on 15th March, before the prospectus copy was delivered to the Registrar on 20th March. Answer: The valuer's statement cannot be included in the prospectus since consent was withdrawn before delivery to ROC. Inclusion would violate Section 26.

### Example 3

Example 3 — Exception Applicability: ABC Ltd issues fresh shares to existing debenture-holders through a prospectus. Answer: The detailed content requirements under Section 26 (a)–(d) do NOT apply to such issue, as it falls under the exception for existing members/debenture-holders.

⚠️ Common exam mistakes

  • Confusing the 90-day rule — students often think it's 90 days from issue to allotment, but it's from ROC filing to public issue.
  • Forgetting that an expert engaged in management/promotion CANNOT give statements — even with consent.
  • Missing that the penalty range is ₹50,000 minimum to ₹3,00,000 maximum (a fine, applicable to the company).
  • Overlooking the two exceptions (existing members/debenture-holders and uniformly quoted securities) when applying content requirements.
  • Confusing Section 2(38) definition of 'expert' — it includes CA, CS, CMA, engineer, valuer, etc.
Bare-Act text Section 26 of the Companies Act, 2013 · The Companies Act, 2013 · click to expand
Section 26 — Matters to be stated in prospectus: Every prospectus issued by or on behalf of a public company shall be dated and signed and shall state such information and set out such reports on financial information as may be specified by SEBI in consultation with the Central Government. It shall also make a declaration about compliance with the Companies Act, SCRA 1956 and SEBI Act 1992. Prospectus must be issued within 90 days of filing with ROC, failing which the issue shall be deemed to be without a prospectus. Contravention: company fine min ₹50,000 up to ₹3,00,000.
Now that you've read this — what's next?
Move from understanding → mastery in 3 clicks. Each option below picks up from this lesson's topic.
Start 15-min diagnostic