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Microlesson · 5-min read

Commencement of Business - Section 10A

# Commencement of Business (Section 10A)

A company having share capital cannot commence business or exercise borrowing powers immediately after incorporation. It must first comply with Section 10A.

## What Must Be Filed?

A declaration in the prescribed form by a director, filed with the ROC, stating that:

> Every subscriber to the Memorandum has paid the value of the shares agreed to be taken by him.

## Time Limit

  • Declaration must be filed within 180 days of incorporation.
  • Only after this filing can the company:
  • Commence its business, OR
  • Exercise its borrowing powers.

## Consequence of Default

If the company fails to file the declaration within 180 days AND is found to be not carrying on any business or operation, the ROC may take action for the removal of the company's name from the Register of Companies (i.e., striking off).

## Flow Chart

```

Incorporation (Day 0)

|

v

Subscribers pay subscription money

|

v

Director files declaration with ROC (within 180 days)

|

v

Company may commence business / borrow

```

## Why this Section Exists

The section ensures the company has actually received its initial capital before it starts trading or incurring debt — protecting creditors and the public.

## Quick Recall

  • Applies to: Companies having share capital
  • Time limit: 180 days
  • Form: INC-20A (in practice)
  • Default consequence: Possible strike-off by ROC

Worked example

### Example 1

Example: Sunrise Ltd was incorporated on 1 Jan 2026 with paid-up capital ₹10 lakh. The two subscribers must pay for their shares, and a director must file the declaration with ROC by 30 June 2026 (180 days). Only then can Sunrise enter into business contracts or take a bank loan.

⚠️ Common exam mistakes

  • Forgetting that Section 10A applies only to companies having share capital — companies limited by guarantee without share capital are outside its scope.
  • Confusing 180 days with 60/30 days (other timelines in incorporation).
  • Missing that the ROC can strike off the company only if both conditions are met — non-filing of declaration AND non-carrying on of business.
Bare-Act text Section 10A · Companies Act, 2013 · click to expand
Section 10A: A company incorporated after the commencement of the Companies (Amendment) Ordinance, 2018 and having a share capital shall not commence any business or exercise any borrowing powers unless— (a) a declaration is filed by a director within a period of one hundred and eighty days of the date of incorporation of the company in such form and verified in such manner as may be prescribed, with the Registrar that every subscriber to the memorandum has paid the value of the shares agreed to be taken by him on the date of making of such declaration; and (b) the company has filed with the Registrar a verification of its registered office.
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