The Ministry of Corporate Affairs vide a circular dated 1st January 2020 has extended the time limit for filing e-form No. BEN-2 without payment of additional fee till 31st March 2020. Prior to this circular, the last date for filing of BEN-2 without payment of additional fee was 31st December 2019.
Form BEN-2 is the declaration that a company is required to file with the registrar under Section 90 of the Companies Act 2013. This declaration is with respect to the Significant Beneficial owners of the company disclosing their interest in the company by way of shareholding or voting rights. Section 90(4) of the Companies Act, 2013 mandates every company to file a declaration in form BEN-2 with the Registrar disclosing his beneficial interest in the company.
The reporting of Significant Beneficial Owner (SBO) notified by the Ministry of Corporate Affairs in February 2019 and for which the e-form BEN-2 was made available for filing with due date as 31st July 2019. But the Ministry of Corporate Affairs received several representations and had decided to extend the due date of filing of Form BEN-2. Prior to this deadline extension, the Ministry vide circulars dated 29th July 2019 firstly extended the date of filing of BEN-2 without payment of additional fee till 30th September 2019; and subsequently by another circular dated on 24th September 2019 extended the date for filing of BEN-2 without payment of additional fee till 31st December 2019, which is again extended to 31st March 2020 by this current circular. After 31st March 2020, additional fee will be payable and accordingly the MCA will announce the due date of filing Form BEN-1 which is a one time declaration by the beneficial owner who holds or acquires significant beneficial ownership in the company.