Dematerialisation of shares- Rule 9B

[Geeta Aggarwal]

Dear Group members,

Greetings of the day.

As per rule 9B before starting a preferential issue by a non-small private company, it is required that all the holdings of promoters should be in demat form. In our private limited company, all the promoters have sent their shares for dematerialization except one non promoter shareholder. In such a situation, could the company make preferential allotment in dematerialization form without  waiting until the process of dematerialization of promoters shares is completed.? or could we file PAS 3now and initiate the corporate action after the process of dematrization of promoters shares is completed? Please guide me on this.

Best Regards,

Geeta Aggarwal

Company Secretary

[Gopal Rathnam]

just this morning i responded to similar query. 

1.  Rule 9B applies to all private companies except  "small companies" (paid-up share capital less than ₹4 crore and turnover less than ₹40 crore ) & Government companies

2. Company can  issue securities only in dematerialised form after June 2025.

3.  Before issuing any new securities (bonus, rights, buyback, etc.), the shareholdings of promoters, directors, and KMP must be mandatorily dematerialised. Other non-promoter-director shareholder has 18 moths from June2025 to Demat their shares. If the company has Dmat details of all the shareholders as on date, PAS 3 can be filed - 

gopalrathnam-9886618696