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Microlesson · 5-min read

Allotment of Securities — Minimum Subscription & Application Money [Sections 38, 39 and 40(3)]

## Allotment of Securities by Company [Sections 38, 39 and 40(3)]

Allotment is the appropriation, out of previously unappropriated capital (Authorised – Issued capital) of the company, that constitutes acceptance of an applicant's offer.

### Pre-requisites for a valid allotment [Section 39]

An allotment to the public cannot be made unless both of the following are satisfied:

#### (1) Minimum Subscription

The amount of minimum subscription stated in the prospectus must have been:

  • Subscribed by the public, and
  • Received as application money by cheque or other instrument.

> Minimum subscription is not applicable in case of an Offer for Sale (OFS).

#### (2) Application Money

At least 5% of the nominal (face) value of the security, or such percentage/amount as SEBI specifies, must be payable on application.

> For an OFS, the full issue price must be payable on application.

### Consequence of failure to achieve minimum subscription

If minimum subscription is not received and application money not received within 30 days of issue of the prospectus (or the period SEBI specifies):

  • Application money must be refunded within 15 days of closure of issue, to the same bank account from which the money was received.
  • On failure to refund within time, directors and officers in default are jointly and severally liable to refund with interest @ 15% p.a.

### Quick summary table

RequirementPublic IssueOffer for Sale (OFS)
Minimum subscriptionRequiredNot required
Application money≥ 5% of face value (or SEBI rate)Full issue price
Refund window if minimum not metWithin 15 days of closure of issue
Interest on delayed refund15% p.a. on directors/officers in default

Worked example

### Example 1

Q. P Ltd. issues a prospectus seeking to raise ₹100 crore with a minimum subscription of ₹90 crore. By the end of 30 days, it has received applications for ₹70 crore only. What must P Ltd. do?

A. Since minimum subscription is not achieved within 30 days of issue of prospectus, P Ltd. must refund all application money within 15 days of closure of the issue, to the same bank account from which it was received. If refund is delayed, the directors and officers in default become jointly and severally liable to refund the money with 15% p.a. interest.

### Example 2

Q. Q Ltd. issues equity at face value ₹10, issue price ₹100, and asks for application money of 30 paise per share. Is this valid?

A. No. Section 39 requires application money of at least 5% of the nominal value (i.e. at least ₹0.50 per share on face value of ₹10) or the percentage SEBI specifies. 30 paise per share fails the minimum and the allotment cannot lawfully proceed.

⚠️ Common exam mistakes

  • Calculating the 5% on issue price instead of nominal/face value — Section 39 uses face value.
  • Treating an OFS as needing minimum subscription — Section 39 carve-out exempts OFS.
  • Refunding to a different account than the one used to receive application money.
  • Forgetting the 15% p.a. interest on directors when refund is delayed.
Bare-Act text Section 39 (read with Sections 38 and 40(3)) · Companies Act, 2013 · click to expand
No allotment of any securities of a company offered to the public for subscription shall be made unless the amount stated in the prospectus as the minimum amount has been subscribed and the sums payable on application for the amount so stated have been paid to and received by the company by cheque or other instrument. The amount payable on application on every security shall not be less than five per cent of the nominal amount of the security or such other percentage or amount, as may be specified by the Securities and Exchange Board by making regulations in this behalf.
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