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Microlesson · 5-min read

Register of Members – Section 88 read with Rules 3 to 7

## Maintenance of Register of Members (Section 88)

Every company must maintain certain statutory registers from the date of registration. Section 88 is the parent provision; specifics are filled in by Rules 3 to 7 of the Companies (Management and Administration) Rules, 2014.

### Registers Required (Section 88(1))

RegisterFormRule
Register of MembersMGT-1Rule 3
Register of Debenture-holders / other Security holdersMGT-2Rule 4
Foreign RegisterRule 7

### Rule 3 – Particulars in Register of Members (MGT-1)

For each member, the register must record:

1. Name, address (registered office address if body corporate), email, PAN/CIN, nationality, name & address of nominee.

2. Date of becoming the member.

3. Date of cessation.

4. Amount of guarantee, if any.

5. Other interest, if any, and instructions regarding sending of notices.

6. Any court/authority order attaching shares or relating to dividends.

7. Hypothecation and pledge of shares.

Holding of each class of equity and preference shares by members residing in or outside India must be shown separately.

### Rule 4 – Register of Debenture/Security Holders (MGT-2)

Maintained separately for each issue of debentures or other securities.

### Rule 5 – Time & Place of Entries

  • Time: Entries must be made within 7 days of approval by the Board or Committee of allotment/transfer.
  • Place: May be kept at –
  • The registered office, OR
  • Any other place in the same city/town/village by passing a special resolution, OR
  • Any other place in India where more than 1/10th of total members reside, by special resolution.
  • Updates: Changes due to death, insolvency, name change, transfer to IEPF, etc., must be recorded.

### Rule 6 – Index of Names

  • Required only if the company has 50 or more members.
  • Entries in the index must be made simultaneously with the register entry.
  • For demat shares, the register and index of beneficial owners maintained by a depository under Section 11 of the Depositories Act, 1996 is deemed to be the index for this Act.

### Rule 7 – Foreign Register

  • May be maintained outside India if authorised by the Articles, in Form MGT-3 notification within 30 days of opening (and on any change/discontinuance).
  • Treated as part of the principal register.
  • Entries made only after Board/Committee approval.
  • A copy of every entry to be transmitted to the registered office in India within 15 days, kept as a duplicate.

### Penalty for Contravention

  • Company: Fine of `3,00,000.
  • Every officer in default: Fine of `50,000.
  • The offence is compoundable.

Worked example

### Example 1

Example 1: ABC Ltd. allots 10,000 shares on 1st March 2024 in a Board meeting. The Register of Members must be updated by 8th March 2024 (within 7 days).

### Example 2

Example 2: XYZ Ltd. has its registered office in Mumbai. To keep the Register of Members in Pune, it must pass a special resolution at a general meeting because Pune is outside Mumbai.

### Example 3

Example 3: DEF Ltd., authorised by its Articles, opens a foreign register in London on 01.04.2024. It must file Form MGT-3 with the ROC by 30.04.2024 (within 30 days).

⚠️ Common exam mistakes

  • Maintaining the index when there are fewer than 50 members – it is unnecessary.
  • Confusing MGT-1, MGT-2 and MGT-3 forms.
  • Forgetting the 7-day rule and updating the register at month-end.
  • Keeping the register at another city without passing a special resolution.
  • Not transmitting copies of foreign register entries to the Indian registered office within 15 days.
Bare-Act text Section 88 read with Rules 3–7 · The Companies Act, 2013 · click to expand
Section 88(1): Every company shall keep and maintain the following registers in such form and in such manner as may be prescribed, namely:— (a) register of members indicating separately for each class of equity and preference shares held by each member residing in or outside India; (b) register of debenture-holders; and (c) register of any other security holders.
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