Deposit and debenture reserve compliance extended due to COVID 19, with other regulatory requirements remaining unchanged.
Extension permits additional time for companies to create the deposit repayment reserve and to make the required investment or deposit for debentures as specified in the earlier circular; this relief responds to COVID 19 related compliance difficulties. The extension is limited to the matters identified in the earlier circular's specified paragraphs and all other regulatory requirements remain unchanged.

Relaxation of charge filing timelines for CHG 1 and CHG 9 permits excluded COVID period reckoning and adjusted fee computation.
Temporary relief excludes the period from 1 March 2020 to 30 September 2020 (or from the charge date to 30 September 2020) from reckoning the statutory filing period for Form CHG-1 and Form CHG-9; if not filed within the excluded period counting resumes from 1 October 2020. Fee treatment: pre March charge filings on or before 30 September 2020 pay fees as on 29 February 2020, thereafter fees are computed by adding days from 1 October 2020 plus the period lapsed until 29 February 2020; post March charges filed before 30 September 2020 pay normal fees, otherwise counting for fees begins effectively from 1 October 2020. Certain filings are excluded from the Scheme.

Virtual meetings for EGMs extended to end of September, permitting VC/OAVM or postal ballot under existing rules.
Companies may continue to hold extraordinary general meetings (EGMs) through video conferencing (VC) or other audio visual means (OAVM), or transact eligible items through postal ballot, in accordance with the procedures and safeguards specified in General Circular No. 14/2020 and General Circular No. 17/2020; this permission is extended until 30th September, 2020 and all other requirements in those Circulars remain unchanged.

Dispatch of notice under section 62(2): failure to post rights issue notices not treated as violation if SEBI circular complied.
Listed companies conducting rights issues opening up to 31st July, 2020, that comply with the SEBI circular of 6th May, 2020, will not be regarded as violating the requirement to dispatch the notice under section 62(2) if they are unable to send that notice by registered post, speed post or courier due to Covid 19 related disruptions.

AGM through video conferencing permitted subject to email delivery of financials, e voting and specified public notice requirements.
Companies may hold Annual General Meetings through video conferencing or other audio visual means subject to conditions: companies required to provide e voting must follow the EGM circular frameworks, restrict special business to unavoidable items, send financial statements by email, publish a vernacular and English public notice detailing meeting and e voting arrangements, enable electronic dividend mandates with postal dispatch where bank details are absent, and count virtual and physical attendees for quorum. Companies not required to provide e voting may hold virtual AGMs only if they already hold email addresses of at least half their members and satisfy prescribed voting power thresholds, must register remaining emails, and comply with similar notice and electronic facilitation requirements.

Filing deadline extension: NFRA-2 submissions allowed from form deployment date for the applicable reporting period.
The Ministry of Corporate Affairs extended the filing time for Form NFRA-2 for the Financial Year 2018-19: the filing period is 210 days from the date the form is deployed on the National Financial Reporting Authority website, issued in continuation of an earlier circular and with the approval of the competent authority.

AGM timing flexibility permits companies affected by pandemic to hold annual meetings within an extended statutory period.
Companies whose financial year (other than the first) ended on 31 December 2019 may hold their annual general meeting within an extended nine-month period from the year end without such conduct being viewed as a violation; references to the AGM due date in the Act or rules are to be construed accordingly for these companies.

E-voting requirement ensures remote electronic notice and voting for company resolutions during COVID-19 restrictions.
Notices for EGMs during COVID-19 may be sent only by e-mail registered with the company or depository; public notices must state that the meeting is via VC or OAVM, provide meeting details, website availability of the notice, methods for members without registered e-mails to register and vote remotely, and contact information. The Chairman must record that all feasible efforts to enable member participation and voting were made. For postal ballots, rule 20 (electronic voting) and the earlier circular apply mutatis mutandis and assent or dissent shall be communicated only through remote e-voting.

Unclaimed funds and shares transfer: temporary fee free electronic filing and e verification relief for IEPF compliance amid COVID 19.
The circular provides temporary procedural facilitation for compliance with obligations to transfer unpaid or unclaimed amounts and related share transfers under the Companies Act and the IEPFA Rules, acknowledging COVID 19 related operational impediments and permitting electronic filing of specified IEPF e forms and e verification of claims through the MCA electronic registry without additional fees, so stakeholders may undertake requisite transfer, accounting and refund actions remotely.

CSR expenditure: contributions to designated disaster and COVID relief qualify; routine wages excluded, limited ex gratia exception applies.
Clarifies that CSR expenditure on COVID 19 qualifies when directed to Schedule VII categories for healthcare and disaster management; contributions to certain national disaster funds are eligible but state relief funds not listed in Schedule VII are not. Ordinary salary/wage payments to employees and casual workers during lockdown are not admissible CSR, while a one time ex gratia payment above wages for COVID 19 may qualify if the Board expressly records it and the statutory auditor certifies the treatment.

Virtual meetings and e voting permit companies to transact urgent shareholder business without holding physical general meetings.
Urgent resolutions (other than ordinary business or matters where a person has a right to be heard) should be passed by companies through postal ballot/e voting, without holding a physical general meeting. If an EGM is unavoidable, it may be held through VC/OAVM with safeguards including recorded transcripts, two way participation, remote e voting provision, counting VC/OAVM attendance for quorum, restrictions on proxy appointments, specified access for auditors and independent directors, disclosure in the meeting notice, member assistance helplines, and filing of resolutions with the Registrar of Companies within sixty days.

LLP settlement scheme: defaulting LLPs may file belated documents with ordinary fees and obtain immunity from prosecution.
The modified LLP Settlement Scheme permits defaulting LLPs to file belated documents due up to 31st August, 2020 by paying ordinary filing fees via MCA-21, with no additional fees, and grants immunity from prosecution for defaults rectified by 30th September, 2020; the scheme excludes LLPs that have applied for striking off under Form 24 and defines key terms.

Companies Fresh Start Scheme allows defaulting companies to regularise filings with normal fees and limited immunity from prosecution.
The Companies Fresh Start Scheme, 2020 permits defaulting companies to file belated documents by paying only normal fees and to obtain immunity from prosecution or penalties strictly insofar as such proceedings relate to delay in filing; applications for immunity require withdrawal of prior appeals, electronic filing of Form CFSS-2020 after documents are taken on file, and must be made within six months of the Scheme's closure, subject to specified exclusions and transitional measures.

Contribution to PM CARES Fund qualifies as CSR expenditure, allowing corporate donations for emergency relief under Schedule activities.
Contributions to the Prime Minister's Citizen Assistance and Relief in Emergency Situations Fund (PM CARES Fund), set up to provide relief in emergencies, are clarified to qualify as CSR expenditure under the Companies Act because Schedule-authorized activities include contributions to Central Government funds for socio-economic development and relief.

Compliance relief under Companies Act: moratorium on late filing fees and extensions for meetings and statutory filings.
The Ministry provided temporary compliance reliefs: waiver of additional fees for late MCA 21 filings from 1 April to 30 September; extension of board meeting interval to 180 days for the next two quarters; deferral of CARO 2020 applicability to FY 2020 21; non treating of missed Independent Director in camera meetings for FY 2019 20 as violations; extensions until 30 June 2020 for deposit repayment reserve and debenture investment compliances; additional 180 days to file Commencement of Business; and relaxation of director residency requirement for FY 2019 20.

CSR funding eligibility for COVID-19 permits health and disaster management spending under Schedule VII, interpreted broadly.
Spending of CSR funds for activities related to COVID-19 is eligible under Schedule VII, permitting use for promotion of health care, including preventive health care and sanitation, and for disaster management; items in Schedule VII are to be interpreted liberally for this purpose, consistent with prior circular guidance, and the clarification is issued with competent authority approval.

Relaxation of additional fees for company annual filings extended for companies in UT J&K and UT Ladakh.
The ministry extended the last date for electronic filing of e-form AOC-4 (including AOC-4 (CFS) and AOC-4 XBRL) and e-form MGT-7 for companies within the jurisdiction of the Union Territory of Jammu & Kashmir and Union Territory of Ladakh, granting waiver of additional fees due to internet disruptions and operational difficulties, as authorised by the competent authority and as a continuation of a prior circular.

Filing obligations for insolvency professionals require electronic submission of appointment orders and documentary attachments via the designated general filing form.
Insolvency professionals must upload their NCLT appointment order in Form INC-28 selecting the IBC option and, while affixing DSC, designate themselves as "CEO" for filing purposes. Thereafter, all statutory filings while a company is under CIRP-including AOC-4 and MGT-7-must be submitted as attachments through e form GNL-2 using the "Filings under IBC" option and recording the NCLT/NCLAT/Court order date for event fields.

Form NFRA-2 filing deadline extended to run from the date of deployment on the NFRA website for FY filing.
The time limit for filing Form NFRA-2 for the reporting period Financial Year 2018-19 is 150 days from the date of deployment of this form on the website of the National Financial Reporting Authority, pursuant to General Circular No. 07/2020.

One time condonation of LLP filing delays enables regularisation with capped late fees and immunity from prosecution.
The Central Government's LLP Settlement Scheme, 2020 permits defaulting LLPs to regularise overdue filings due up to 31 October 2019 by paying a nominal additional fee (subject to a cap) alongside the standard filing fee for specified forms (Form 3, Form 4, Form 8, and Form 11), and grants immunity from prosecution by the Registrar for defaults regularised under the scheme; LLPs that have applied for striking off are excluded and Registrars will proceed with enforcement against non participating defaulters after the scheme ends.