Issue of Debentures (S.71)
Issue debentures: Board + SR (if convertible), appoint trustee, create DRR, register charge. Issue of Debentures (S.71) takes 7 steps over about 133 days and is filed with the ROC on CHG-9 and PAS-3.
Last updated: 10 August 2026
What if it’s filed late?
MCA charges additional fees that rise with the delay, up to 12 times the normal filing fee. OnCompliance tracks the date and warns you before it costs anything.
What is the timeline for Issue of Debentures (S.71)?
7 steps over about 133 days, filing CHG-9 and PAS-3 with the ROC. Each deadline below runs from the step before it.
| # | Step | Form filed | Deadline |
|---|---|---|---|
| 1 | Board Approves Debenture Issue | None | within 7 days |
| 2 | Pass SR (if convertible) | None | within 30 days |
| 3 | Appoint Debenture Trustee | None | within 14 days |
| 4 | Create Debenture Redemption Reserve | None | within 7 days |
| 5 | Issue Debentures | None | within 30 days |
| 6 | File CHG-9 (Charge for Debentures) | CHG-9 | within 30 days |
| 7 | File PAS-3 | PAS-3 | within 15 days |
What are the steps, in order?
The 7 steps below run in order; the day counts show how long each one allows.
Board Approves Debenture Issue
Board approves terms of debenture issue.
Pass SR (if convertible)
SR required for issue of convertible debentures.
Appoint Debenture Trustee
Appoint a debenture trustee before issue.
Create Debenture Redemption Reserve
Create DRR of at least 10% for listed companies.
Issue Debentures
Allot debentures and collect subscription money.
File CHG-9 (Charge for Debentures)
Register charge on assets for secured debentures.
File PAS-3
File return of allotment within 15 days.
Every guide runs like this in OnCompliance: steps in order, dates in view, paperwork made for you at each step.
Common questions
How long does Issue of Debentures (S.71) take?
About 133 days across 7 steps. The first step is: Board Approves Debenture Issue.
Which MCA forms are filed for Issue of Debentures (S.71)?
CHG-9 and PAS-3. PAS-3 is the return of allotment filing under §39 of the Companies Act 2013.
What does it cost if CHG-9 and PAS-3 are filed late?
MCA charges additional fees that rise with the delay, up to 12 times the normal filing fee.
Can OnCompliance run Issue of Debentures (S.71) for me?
Yes. OnCompliance runs the same steps in order, dates in view, with the paperwork made for you at each step.