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Microlesson · 5-min read

Steps & Procedure for Incorporation of a Company (SPICe+ Filing)

# Incorporation of a Company — Step-by-Step Procedure

## Nine-Step Roadmap

1. Determine nature of company (Private / Public / OPC / Section 8 / Nidhi).

2. Reserve a name by filing the prescribed application (Part A of SPICe+).

3. Draft & sign the MOA and AOA.

4. Submit MOA & AOA along with other documents to the Registrar of Companies (ROC).

5. Consent (DIR-2) of persons named as the first directors.

6. Statutory declaration of compliance (Form INC-8).

7. Pay fees and stamp duty.

8. Receive Certificate of Incorporation (Form INC-11).

9. File declaration regarding the registered office address and a declaration that subscribers have paid the value of shares subscribed — both required before commencement of business.

## Filing with the Registrar [Sec 7(1)]

The application is filed with the ROC having jurisdiction over the proposed registered office, using SPICe+ (INC-32) with the fee prescribed under the Companies (Registration Offices and Fees) Rules, 2014.

### Forms to remember

FormPurpose
SPICe+ (INC-32)Integrated incorporation application
e-MOA (INC-33)Electronic Memorandum
e-AOA (INC-34)Electronic Articles
INC-8Declaration of compliance by professional / first director
INC-9Declaration by every subscriber & first director (no conviction, no fraud, info correct)
INC-11Certificate of Incorporation issued by ROC
DIR-2Consent to act as director
DIR-12Particulars of appointment of directors

## Signing the MOA & AOA [Rule 13, Companies (Incorporation) Rules, 2014]

Subscriber typeHow to sign
IndividualSign with name, address, description, occupation; in presence of one witness who also attests with his particulars.
IlliterateAffix thumb impression — described by the writer, who authenticates with his own signature and notes the number of shares.
Body CorporateSigned by a director, officer or employee duly authorised by a Board Resolution.
LLPSigned by a partner authorised by a resolution of all partners.
Foreign nationalSignatures, address & ID notarised by a Notary Public. If from a non-Commonwealth/non-Hague Apostille country, also authenticated by Diplomatic / Consular Officer.

> A person authorised to sign on behalf of a body corporate / LLP cannot simultaneously be a subscriber in his own capacity.

## Foreign Nationals Visiting India

Incorporation by a foreign national who is in India is allowed only if he holds a valid Business Visa. Persons of Indian Origin (PIO) and Overseas Citizens of India (OCI) are exempt from this Business Visa requirement.

## Declarations Required

1. INC-8 — Declaration of Compliance: filed by (a) an Advocate / CA / CMA / CS in practice engaged in formation, and (b) a person named in the articles as director, manager or secretary.

2. INC-9 — Declaration by Subscribers & First Directors: each subscriber and first director declares that:

  • All filed documents contain information that is correct, complete and true;
  • He has not been convicted of any offence in connection with promotion/formation/management of any company; and
  • He has not been found guilty of fraud, misfeasance, or breach of duty to any company under this Act or any previous company law during the last five years.

3. Address for correspondence till the registered office is established.

4. Particulars of first directors — name, DIN, residence, nationality, identity proof, interest in other firms/bodies corporate, consent in DIR-2, filed in DIR-12.

## Particulars of Subscribers to the MOA

(a) Name + recent photograph; (b) Father’s/Mother’s name; (c) Nationality + proof if foreign; (d) Date and place of birth (District & State); (e) Educational qualification and occupation; (f) PAN; (g) Email & phone; (h) Permanent & present address; (i) Residential proof — bank statement / electricity / telephone or mobile bill not older than 2 months; (j) Identity proof — Indians: Voter ID / Passport / DL / UID; Foreigners / NRIs: Passport; (k) If already a director/promoter of another company, the CIN and capacity (director/promoter) must be given.

## If Subscriber Is a Body Corporate

File: name & CIN/registration number; GLN (if any); registered office / principal place of business; email ID; certified true copy of Board Resolution authorising subscription (or partners' resolution if LLP/firm); for foreign bodies corporate — copy of certificate of incorporation and registered office address.

## Sectoral Regulator Approval [Rule 12]

If any object requires approval from a sectoral regulator (e.g., RBI, SEBI), the approval must be obtained before pursuing the object and a declaration to that effect filed at incorporation. For a Nidhi company, the Section 406 declaration of the Central Government must be obtained before commencing business, and a declaration filed at incorporation.

## Issue of Certificate of Incorporation [Sec 7(2)]

On satisfaction of documents, the ROC registers them and issues the Certificate of Incorporation in Form INC-11, which mentions the PAN allotted by the Income-tax Department. From this date the company is born as a separate legal person.

Worked example

### Example 1

Example 1 — Foreign subscriber: Mr. X, a French national resident in Paris, wants to subscribe to the MOA of an Indian company. What is the additional formality?

Answer: His signatures, address and identity proof must be notarised by a Notary Public in France. As France is a party to the Hague Apostille Convention, 1961, no further Consular/Diplomatic authentication is required.

### Example 2

Example 2 — Body corporate subscriber: Alpha Ltd wants to subscribe to the MOA of NewCo Pvt Ltd. Who signs and what is filed?

Answer: A director/officer/employee of Alpha Ltd, duly authorised by a Board Resolution, signs the MOA on Alpha Ltd's behalf. A certified true copy of the Board Resolution must be filed with the ROC. The signatory cannot simultaneously be subscribing in his individual capacity.

### Example 3

Example 3 — INC-9 declaration: Mr. Y, the first director of PQR Ltd, was convicted of fraud in 2024. PQR Ltd is being incorporated in 2026. Can he make the INC-9 declaration?

Answer: No. INC-9 requires a declaration that the subscriber/first director has not been found guilty of fraud during the last five years. Mr. Y is disqualified from signing INC-9 within five years of the conviction.

⚠️ Common exam mistakes

  • Confusing INC-8 (compliance declaration by professional/director) with INC-9 (declaration by subscriber/first director regarding correctness and absence of conviction).
  • Treating SPICe+ (INC-32) and INC-7 as interchangeable — INC-7 has been discontinued; SPICe+ is the integrated form.
  • Forgetting that residential proof must be not more than 2 months old.
  • Skipping the sectoral regulator approval declaration when objects fall under RBI/SEBI/IRDAI etc.
  • Allowing the same person who is authorised by a body corporate to also subscribe in his individual capacity — this is prohibited.
  • Forgetting that PIOs and OCIs are exempt from the Business Visa requirement when incorporating from within India.
Bare-Act text Section 7 of Companies Act, 2013; Rules 12 & 13 of Companies (Incorporation) Rules, 2014 · Companies Act, 2013 read with Companies (Incorporation) Rules, 2014 · click to expand
Section 7(1) — There shall be filed with the Registrar within whose jurisdiction the registered office of a company is proposed to be situated, the following documents and information for registration, namely — (a) the memorandum and articles of the company duly signed by all the subscribers to the memorandum in such manner as may be prescribed; (b) a declaration in the prescribed form by an advocate, a chartered accountant, cost accountant or company secretary in practice, who is engaged in the formation of the company, and by a person named in the articles as a director, manager or secretary of the company, that all the requirements of this Act and the rules made thereunder in respect of registration and matters precedent or incidental thereto have been complied with; (c) a declaration from each of the subscribers to the memorandum and from persons named as the first directors, if any, in the articles that he is not convicted of any offence in connection with the promotion, formation or management of any company, or that he has not been found guilty of any fraud or misfeasance or of any breach of duty to any company under this Act or any previous company law during the preceding five years and that all the documents filed with the Registrar for registration of the company contain information that is correct and complete and true to the best of his knowledge and belief; ... Section 7(2) — The Registrar on the basis of documents and information filed under sub-section (1) shall register all the documents and information referred to in that sub-section in the register and issue a certificate of incorporation in the prescribed form to the effect that the proposed company is incorporated under this Act.
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