When a company raises a term loan, opens a working capital limit, or issues debentures, lenders require security over business assets, and that security must be formally registered with the Registrar of Companies under Section 77 of the Companies Act 2013. Yet most founders and finance teams focus only on the loan negotiation and miss the statutory window. If the charge is not filed within 30 days of its creation, every day of delay attracts a penalty of Rs 1,000 under Section 86, and worse, the charge becomes void against the liquidator and other creditors, leaving the lender with no enforceable security. That is not a compliance technicality; it is a commercial risk that can unravel a entire credit arrangement. KAMRIT prepares your e-Form CHG-1 or CHG-4 end to end, cross-checks the charge instrument for completeness, obtains the charge holder's consent, files on the MCA21 portal, and follows up with the RoC until the certificate of registration is in your hand. We handle every stage from document review to final SRN confirmation so that your loan disbursement is not held up by a filing oversight.
What is Charge Filing (CHG-1, CHG-4) in India 2026?
A charge under the Companies Act 2013 is a legal interest a company grants to a lender over its assets or property to secure repayment of a loan or credit facility. Section 77 requires every company that creates such a charge, whether a mortgage on immovable property, a hypothecation over plant and machinery, a debenture trust deed, or a charge on book debts, to file the prescribed e-Form with the Registrar of Companies within 30 calendar days of the charge being created. The filing is made on the Ministry of Corporate Affairs MCA21 portal using Form CHG-1 for creation and modification, and Form CHG-9 for satisfaction when the loan is repaid. If the company fails to file within the prescribed period, it may apply to the RoC under Section 79 for condonation of delay, though late filing fees apply. The consequences of non-filing are severe: under Section 86, every officer in default is liable to a fine of up to Rs 50,000, and the unregistered charge is void against any liquidator or creditor, making it worthless security for the lender. The MCA maintains a Register of Charges accessible to any applicant on payment of prescribed fees under Section 81.
Who needs this
Charge filing applies to every Indian company that creates a registrable security interest. The following conditions trigger a filing obligation under Section 77 of the Companies Act 2013.
- Company incorporated and registered under the Companies Act 2013 or the earlier Companies Act 1956, with an active MCA DIN and PAN.
- Term loan, working capital facility, or cash credit limit sanctioned by any scheduled bank, private bank, NBFC, or financial institution.
- Creation of a mortgage or charge over any immovable or movable property of the company, whether at creation of the charge or subsequently.
- Issuance of debentures whether secured by a trust deed or a floating charge over the company's assets.
- Equipment or vehicle financed under a hire-purchase or lease arrangement where the financier retains a security interest pending final payment.
- Charge created over existing assets of a business being acquired, where the charge is assumed by the acquiring company as part of the takeover.
- Modification or augmentation of an existing charge, including additional borrowing, changed security terms, or extension of the charge period, requiring Form CHG-4 filing with the RoC.
- Satisfaction of a charge when a loan is fully repaid and the company wishes to remove the encumbrance from the MCA records, requiring Form CHG-4 or CHG-9 with the RoC.
- Charge created by a foreign company over assets situated in India, required to be filed under Section 77(1)(b) read with Section 379.
- Charges on book debts, receivables, or inventory created as working capital security, also registrable under Section 77(1)(d).
Documents required
The strength of a charge filing lies in the quality and completeness of the instrument creating the charge. Incomplete or unsigned charge deeds are the primary reason for RoC rejections and resubmissions, which delay loan disbursement by weeks.
- Sanction letter or loan agreement from the bank or financial institution specifying the loan amount, interest rate, security terms, and charge creation date, the primary trigger document for the filing.
- Executed mortgage deed, deed of hypothecation, or debenture trust deed, signed by the company and the charge holder, stamped as per the applicable State Stamp Act and notarised if required for immovable property.
- Form CHG-1 completed with the charge holder's name as per the MCA records, the secured asset description, the charge amount, and the date of creation, attached as a pre-fill document to the e-Form filing.
- Board resolution under Section 179(3)(f) of the Companies Act 2013 authorizing the creation of the charge, signed by the company secretary or a director and listing all director DINs.
- Consent letter from the charge holder explicitly authorizing the company to file the charge registration with the RoC, required by the MCA as a mandatory attachment to prevent unilateral filings.
- Original or certified copy of the memorandum of association and articles of association, to verify that the company has the power to create charges over its assets.
- Encumbrance certificate from the sub-registrar or the relevant register for immovable property, confirming no prior unregistered charges exist on the asset.
- Identity and address proof of the authorized signatory filing the form: PAN card, DIN, and a recent utility bill or bank statement as address confirmation.
- For charge modification (CHG-4): original SRN of the charge creation filing, supplemental deed or amendment agreement, and updated board resolution for the modification terms.
- For charge satisfaction (CHG-9 or CHG-4): no-objection certificate or release letter from the charge holder confirming full repayment and requesting removal of the charge from the MCA register.
How KAMRIT runs it, step by step
KAMRIT follows a structured eight-step process from intake to final certificate, managing both the preparational work within our control and the follow-up with the RoC for stages that depend on the regulator.
- Document Collection and Review. The client shares the sanction letter, executed charge deed, board resolution, and charge holder consent. KAMRIT reviews every document for completeness: verifying that the charge deed is properly stamped, that the charge holder name matches their MCA-registered name, that the charge amount and date of creation are unambiguous, and that all required signatures are present. If the instrument is unsigned, unstamped, or missing a page, we flag it immediately so the client can rectify it before the MCA filing window closes.
- DIN and DSC Verification. The authorized signatory filing the form must have a valid Director Identification Number and a Digital Signature Certificate registered with the MCA. KAMRIT verifies the DSC's validity and ensures the signatory's DIN is active and not deactivated. If the DIN is not registered or the DSC has expired, we assist with fresh DIN application or DSC renewal before proceeding, a step many firms overlook until the filing stage.
- Form CHG-1 or CHG-4 Preparation. KAMRIT prepares the e-Form on the MCA21 portal. For charge creation, Form CHG-1 is completed with the charge holder details, secured asset description, charge amount, nature of charge (fixed, floating, or both), date of creation, and the total amount secured including any interest. For modifications, Form CHG-4 captures the nature of modification, whether a change in charge amount, additional security, or charge holder name change. Each field is cross-referenced against the charge instrument to prevent mismatches that lead to RoC queries.
- Supporting Attachments Upload. The executed charge instrument, board resolution, consent letter, property documents, and NOC are uploaded as attachments to the e-Form. KAMRIT ensures attachments are in PDF format, within the size limits prescribed by the MCA, and clearly labeled. For immovable property charges, the registered deed is attached, not a copy of the original registration receipt. This distinction is critical and a frequent cause of RoC query letters.
- Pre-submission QA Check. Before filing, KAMRIT performs a line-by-line QA on the complete form: verifying the charge amount in figures and words matches the sanction letter, confirming the charge creation date is accurate, cross-checking the charge holder name against their PAN and GST records, and ensuring the DSC is applied by the correct authorized signatory. Any discrepancy at this stage is far cheaper to fix than after a rejected filing.
- MCA21 Portal Submission and SRN Generation. The completed e-Form is filed on the MCA21 portal (v3). Upon successful submission, the portal generates a Service Request Number (SRN). KAMRIT shares the SRN with the client immediately, along with the filing details and the MCA's estimated processing timeline of 3 to 5 working days. The filing date is the date on the SRN, not the date of the certificate, and this is the date that determines whether the filing is within the statutory 30-day window.
- RoC Processing and Follow-up. The RoC processes the e-Form and either approves it with a Certificate of Registration (CRC) under the MCA portal or raises a deficiency query. KAMRIT monitors the MCA inbox daily for the SRN status and follows up with the RoC through the MCA portal's query response mechanism. Common queries relate to attachment quality, consent letter format, or charge amount discrepancies, all of which we address in the first response to avoid a second-round query.
- Certificate Delivery and Final Report. Once the RoC approves the filing, KAMRIT downloads the Certificate of Registration of Charge or the Memorandum of Satisfaction and delivers it to the client. We also provide a charge filing report showing the filing date, SRN, certificate number, charge details, and next due date, useful for the company's compliance calendar and for the lender's records. For CHG-4 satisfaction filings, we also confirm the charge has been removed from the MCA's public Register of Charges.
Timeline
From the date KAMRIT receives complete documents, charge deed, board resolution, consent letter, and sanction letter, the preparation and QA stage takes 2 to 3 working days. The e-Form filing itself is submitted within this window, generating the SRN. The RoC then processes the filing within 3 to 5 working days, after which the Certificate of Registration of Charge is issued under the MCA portal. In normal circumstances, KAMRIT delivers the complete filing confirmation within 6 to 10 working days from document receipt. If the RoC raises a deficiency query, the timeline extends to 12 to 15 working days, the query response and resubmission adds 4 to 6 working days. Government holidays, MCA portal downtime, and RoC workload in high-volume states like Delhi or Maharashtra can add another 2 to 3 working days. For charges created more than 30 days ago (late filings), KAMRIT first files an application under Section 79 for condonation of delay with the RoC, this pre-filing step adds 5 to 8 working days. The statutory 30-day window under Section 77 runs from the date the charge was created, not from the date of the filing. KAMRIT tracks this window from the moment of intake and flags any risk of late filing before it becomes a penalty issue.
How our pricing compares
KAMRIT's charge filing service starts at Rs 1,899, an all-inclusive professional fee covering document preparation, e-Form filing, DSC attestation, and RoC follow-up until certificate issuance. Government filing fees of Rs 600 for charges up to Rs 5 lakh (Rs 1,000 for Rs 5-10 lakh and Rs 1,200 for above Rs 10 lakh as per MCA Gazette Notification GSR 426(E) dated May 24, 2016) are charged at actuals and shared transparently. Stamp duty on the charge instrument varies by state, Rs 500 in Maharashtra for mortgage deeds, zero in some states, and is borne by the client separately. IndiaFilings charges Rs 2,499 for a standard CHG-1 filing with government fees extra and a 7-12 working day turnaround; their fee does not include handling RoC queries or resubmissions. Vakilsearch charges Rs 2,999-4,999 depending on charge complexity, with a stated 8-15 working day timeline and government fees additional. LegalRaasta offers CHG-1 filing at Rs 2,299-3,799 but their package excludes pre-filing document QA and RoC query handling, which are billed separately. ClearTax does not offer a standalone CHG-1 service. KAMRIT's price is lower than most competitors because we have standardized our intake and QA process for charge filings, we handle volume, which keeps per-engagement costs down. Unlike competitors who charge separately for each amendment, query response, or follow-up call, KAMRIT's Rs 1,899 fee is comprehensive until the certificate is in hand. For clients with multiple charges or complex charge structures involving multiple properties and lenders, we provide a custom quote that accounts for the additional instrument review and attachment preparation without charging a blanket premium.
Common mistakes KAMRIT avoids
Charge filing errors are disproportionately costly because they involve both regulatory penalties and commercial risk to the lender's security. The following mistakes are the most common reasons why filings are rejected, delayed, or become unenforceable.
- Missing the 30-day deadline under Section 77, even a one-day delay attracts Rs 1,000 per day in late fees under Section 86, and in extreme cases the RoC may not accept a condonation application at all.
- Filing CHG-1 for satisfaction instead of CHG-9 or CHG-4, using the wrong form is a rejection-level error that resets the compliance timeline and may require re-filing with fresh fees.
- Not attaching the executed charge instrument, the MCA has rejected filings where only the sanction letter was attached; the mortgage or hypothecation deed itself is mandatory.
- Charge holder consent missing or in the wrong format, the RoC requires a specific consent letter from the charge holder authorising the company to file. A generic no-objection letter is not accepted.
- Charge amount mismatch between the form and the sanction letter, if the charge amount on CHG-1 differs from the sanctioned loan amount (even by including accrued interest), the RoC may query it and the lender's priority ranking is affected.
- Incorrect charge holder name, filing with the lender's legal entity name as per MCA records (not the branch name or the dealing officer's name) is mandatory. Filing with a wrong name creates a charge that is unenforceable.
- Not filing for modification when the charge is augmented, if a second loan is added to an existing charge, CHG-4 must be filed within 30 days of the modification agreement, not only when the first loan is repaid.
- Assuming the filing is the lender's responsibility, the legal obligation to file lies with the company (borrower). If the lender files first without the company's involvement, the company is still in default under the Act.