Clarification on Demat Compliance Applicability

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Anupma Mittal

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Apr 28, 2026, 6:21:42 AMApr 28
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Dear All,

Please claify if the turnover of small company for the FY 2024-25 crossed 40 crores. So is there requirement of demat compliance as now the definition of small company has changed . 

Please confirm.

Thanks

CA Rajesh Sewlani

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Apr 28, 2026, 6:29:41 AMApr 28
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if turnover for

March 2024  > 20 crore
March 2025 > 40 crore
March 2026 > 100 crore

The company is required to convert the shares in DEMAT 

change of small company definition was effective from December 2025 so till 30th November, turnover limit was 40 crore.  it should have been done before that



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Regards,

CA Rajesh Sewlani

 Chartered Accountants

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CS Pinki Gupta

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Apr 28, 2026, 6:37:06 AMApr 28
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If the company takes the ISIN and facilitates the shareholder in 2025, But now in 2026 the company is a Small Company. Then can the company apply for cancellation of ISIN? 

Arun Kumar Maitra

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Apr 28, 2026, 9:05:24 AMApr 28
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Yes, if your company’s turnover for FY 2024-25 exceeds ₹40 crore, it may lose the "small company" exemption. However, the definition was revised effective December 1, 2025, to a turnover of up to ₹100 crore and paid-up capital of ₹10 crore. If your company meets the revised thresholds, it remains a small company.If not,mandatory demat compliance is required.
CA CS Arun Kumar Maitra
 

Sujoy Sircar

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Apr 28, 2026, 9:48:20 AMApr 28
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What about an Indian WoS of a foreign company? Will the WoS be able to take the exemption based on turnover thresholds. 
Your thoughts..

Sujoy Sircar (ACS, LLM)

Vinod Kumar Agarwal

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Apr 28, 2026, 9:51:15 AMApr 28
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Exemptions not applicable to Holding/Subsidiary companies

CA.Prashant Raichura

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Apr 29, 2026, 1:29:06 AMApr 29
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My Query as under:

·      Earlier, the Company did not qualify as a “Small Company” under Section 2(85) of the Companies Act, 2013 and was accordingly covered under the mandatory dematerialisation provisions.


However as per the Amended Definition of Small Company, Company Qualifies as Small Company (Current Scenario): The Company is exempt from applicability of Rule 9A.




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Thanks & Regards
CA. Prashant Raichura
B. B. Shah & Company
Chartered Accountants
Gr. Floor Rajguru Apts Baburao Parulekar Road
Dadar West Mumbai | Cell 7977179129 
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