Compliance Pack
Significant beneficial owner declaration, BEN-1 / BEN-2
What this means, checked by a CA
If a person controls 10% or more of your company through another entity, they must declare it to the company (BEN-1) and the company must report it to the ROC (BEN-2) within 30 days. We trace the ownership chain, collect the declarations and file.
₹2,499
As needed, + 18% GST
- Delivered in 3 working days after the ownership chart
- Due: BEN-1 within 30 days of becoming SBO or any change; BEN-2 within 30 days of receiving BEN-1
How we do it: IDFD
Every case runs through the same four steps: Information, Discussion, Forms, Deliverables. You see each one ticked as it happens.
InformationWhat we need from you · 8 items
Shareholding chart up to individuals
Find who crosses 10%
Register of members, latest
Starting point for tracing
Corporate shareholders' own holding data
Majority stake test
Signed BEN-1 from each SBO
Basis for BEN-2
SBO PAN or passport, address
Particulars in BEN-2
Date company received BEN-1
Starts the 30-day clock
Trust deed or fund documentsOptional
Trustee, settlor or manager test
Board resolution authorising filingOptional
Signatory for BEN-2
DiscussionWhat we discuss · 5 items
Which shareholders are not individuals (companies, LLPs, firms, trusts, HUFs, funds) and hold 10% or more?
Triggers tracing and BEN-4 notices
Who holds the majority stake in each corporate shareholder, up to the ultimate holding company?
Majority holder is treated as SBO
Does anyone have special rights such as board seats or vetoes under an SHA?
May be significant influence or control
Is any shareholder exempt (government, SEBI or RBI regulated vehicle, holding reporting company)?
Rule 8 exemptions
When did the change happen and when was BEN-1 received?
Fixes both 30-day deadlines
FormsForms we file · 4 items
Map the ownership chain and identify SBOs; send BEN-4 notices to non-individual members holding 10% or more and to suspected SBOs
Where: Internal. Due: On any change in shareholding
Collect BEN-1 from each SBO
Where: Internal. Due: Within 30 days of the SBO acquiring status or any change
Enter details in the register of SBOs, BEN-3
Where: Internal. Due: On receipt of BEN-1
File BEN-2 with SBO details, layer by layer
Fee by authorised capital slab; late: 2x to 12x by delay band
Where: https://www.mca.gov.in. Due: Within 30 days of receiving BEN-1
DeliverablesWhat you get · 3 items
BEN-2 SRN and challan
When: Same day as filing
BEN-1 declarations and BEN-3 register
When: With filing
Ownership chart note
When: With filing
Questions people ask
If an individual holds 10% directly, is that an SBO?
Not by direct holding alone. The 10% test applies to indirect holding, or indirect plus direct, or to control through other means.
Who files BEN-1?
The individual SBO gives BEN-1 to the company, not to the ROC.
What if the SBO does not respond?
The company sends a BEN-4 notice seeking the information.
What are the penalties?
Individual: ₹50,000 plus ₹1,000 a day up to ₹2 lakh. Company: ₹1 lakh plus ₹500 a day up to ₹5 lakh. Officer: ₹25,000 plus ₹200 a day up to ₹1 lakh.
Are compulsorily convertible preference shares counted?
Yes. CCPS, CCDs and GDRs count as shares for this test.
Your Savvy is a verified professional. Every paid answer is checked by a CA. Free AI answers are labelled until a CA verifies them.