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Microlesson · 5-min read

Section 40 - Securities to be Dealt with in Stock Exchanges & Underwriting Commission

## Section 40 — Securities to be Dealt with in Stock Exchanges

### Requirement before public offer

Every company making public offer shall, BEFORE making such offer:

  • Make an application to one or more recognised stock exchanges, AND
  • Obtain permission for the securities to be dealt with in such stock exchange(s).

### Prospectus must state

1. That application has been made to the recognised stock exchange(s).

2. The name(s) of such stock exchange(s).

### Separate bank account for application money

Application money shall be kept in a separate bank account in a Scheduled Bank and shall be utilised only for:

  • Adjustment against allotment of securities (where stock exchange permission is granted), OR
  • Repayment of application money to applicants in case the company is unable to allot (e.g., listing permission refused).

### Default — penalty

The company and every officer in default: punishable with fine.

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### Underwriting Commission

A company may pay commission to underwriters subject to the following conditions:

ConditionRequirement
AOA authorisationArticles must authorise the payment
SourceOut of proceeds of issue OR profits of the company
Maximum rate — Shares5% of issue price OR rate fixed in AOA (whichever is LESS)
Maximum rate — Debentures2.5% of issue price OR rate fixed in AOA (whichever is LESS)
Disclosure in prospectusName of underwriter and rate of commission must be stated
No commissionIf securities are NOT offered to public
Underwriting contractMust be filed with ROC at the time of registration

Worked example

### Example 1

Example: ABC Ltd. plans an IPO. Before issuing the prospectus, it must apply to BSE/NSE and obtain in-principle listing approval. The prospectus must name BSE/NSE and confirm application made.

### Example 2

Example: Company's AOA authorises underwriting commission @ 6% on shares. Maximum permissible is 5% under Section 40. Therefore the company can pay only 5%.

### Example 3

Example: Company makes a private placement (not public offer). No underwriting commission can be paid as the securities are not offered to public.

⚠️ Common exam mistakes

  • Forgetting that the application money MUST go to a separate scheduled bank account — cannot be mixed with general funds.
  • Confusing maximum commission limits: 5% for shares, 2.5% for debentures.
  • Not realising commission needs BOTH AOA authorisation AND must not exceed statutory ceiling.
  • Missing that prospectus must NAME the stock exchange — not just say 'application made to a recognised stock exchange'.
Bare-Act text Section 40 · Companies Act, 2013 · click to expand
Every company making public offer shall, before making such offer, make an application to one or more recognised stock exchange or exchanges and obtain permission for the securities to be dealt with in such stock exchange or exchanges. All monies received on application from the public for subscription to the securities shall be kept in a separate bank account maintained with a Scheduled Bank and shall not be utilised for any purpose other than for adjustment against allotment of securities or for repayment of monies received from applicants where the company is for any other reason unable to allot securities.
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