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

Promoter — Meaning, Definition & Status

# Promoter [Section 2(69)]

## Meaning (Concept)

A promoter is a person — individual, firm, company, etc. — who performs the preliminary duties necessary to bring a company into being and float it. The promoter:

  • Conceives the business idea, develops it, and induces others to join;
  • Gathers the subscribers to the Memorandum;
  • Gets the MOA & AOA prepared, executed and registered;
  • Engages the bankers, brokers and legal advisers;
  • Identifies the first directors;
  • Settles the terms of preliminary contracts with vendors; and
  • Arranges for preparation, advertisement, circulation of the prospectus and placement of capital.

## Statutory Definition [Sec 2(69)]

"Promoter" means a person —

  • (a) who has been named as such in a prospectus, or is identified by the company in the annual return referred to in Section 92; or
  • (b) who has control over the affairs of the company, directly or indirectly, whether as a shareholder, director or otherwise; or
  • (c) in accordance with whose advice, directions or instructions the Board of Directors of the company is accustomed to act.

> Exception: A person acting merely in a professional capacity (e.g., a solicitor, an accountant) on behalf of the promoter and paid by him is NOT a promoter.

## Visualising the Test

Think of it as three independent gateways — satisfying any one makes a person a Promoter:

1. Named (prospectus / annual return); or

2. Controls (shareholder/director/otherwise); or

3. Shadow Promoter (Board accustomed to act on his instructions).

Worked example

### Example 1

Example 1: Mr. R’s name appears in the prospectus of ABC Ltd as a promoter. He owns no shares and is not on the Board. Is he a Promoter?

Answer: Yes — under limb (a), being named in the prospectus alone is sufficient.

### Example 2

Example 2: A Chartered Accountant in practice helps Mr. R draft the MOA, AOA and prospectus, and is paid professional fees. Is the CA a Promoter?

Answer: No. Acting merely in a professional capacity for a fee does not make him a promoter (statutory exclusion).

⚠️ Common exam mistakes

  • Treating every signatory to the MOA as a 'promoter' — they are subscribers; promoter status requires the Sec 2(69) tests.
  • Forgetting limb (c) — the 'shadow promoter' covers a person who never appears on records but whose instructions the Board follows.
  • Calling solicitors/CAs/CSes acting in professional capacity 'promoters'.
Bare-Act text Section 2(69) · Companies Act, 2013 · click to expand
Section 2(69) — "promoter" means a person — (a) who has been named as such in a prospectus or is identified by the company in the annual return referred to in section 92; or (b) who has control over the affairs of the company, directly or indirectly whether as a shareholder, director or otherwise; or (c) in accordance with whose advice, directions or instructions the Board of Directors of the company is accustomed to act: Provided that nothing in sub-clause (c) shall apply to a person who is acting merely in a professional capacity.
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