TaxTMI 
TaxTMI 
A Pvt. Ltd company which was a small company until 31st March,2025, became a non small company in May 2025 by increasing its paid up capital. It has not yet obtained ISIN because of 18 months window available as per Rule 9B of Prospectus and allotment rules. So is such a company required to file PAS 6 for the half year ending Sep, 2025? As PAS 6 cannot be filed without ISIN, would this constitute as non-compliance?
ISIN requirement and PAS 6 filing
21 Nov 2025 
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ISIN requirement for a company becoming non-small does not mandate PAS-6 filing for Sep 2025 half-year.
The obligation to obtain an ISIN and to dematerialise securities under Rule 9B is subject to a transition window; Form PAS-6 presumes an ISIN for reporting where dematerialisation is mandatory. If a company that became non-small in May 2025 remains within the Rule 9B transition period and lacks an ISIN, PAS-6 cannot be completed and non-filing for the half-year ending 30 September 2025 does not constitute non-compliance while the transition timeline applies. (AI Summary)
The obligation to obtain an ISIN and to dematerialise securities under Rule 9B is subject to a transition window; Form PAS-6 presumes an ISIN for reporting where dematerialisation is mandatory. If a company that became non-small in May 2025 remains within the Rule 9B transition period and lacks an ISIN, PAS-6 cannot be completed and non-filing for the half-year ending 30 September 2025 does not constitute non-compliance while the transition timeline applies. (AI Summary)