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ESOP SH-6 Register Administration

Reviewed by CA and CS Team, Patron Accounting LLP ICAI & ICSI Registered| 15+ Years Experience| Last Updated: Verify Credentials →

Records: grants, vesting, exercises, lapses and forfeitures, scrip by scrip.

Fees: annual SH-6 administration from Rs 9,999 per year (Exl GST and Govt. Charges).

Mandatory under: Rule 12(10), Companies (Share Capital and Debentures) Rules.

Penalty avoided: Section 450, Rs 10,000 plus Rs 1,000 per day of default.

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    Startups and growth companies trust Patron Accounting to keep the SH-6 register current, authenticated, reconciled and due-diligence-ready year round.

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    What This Service Covers

    📌 TL;DR - SH-6 Register Administration Services at a Glance

    Form SH-6 is the statutory Register of Employee Stock Options every company issuing ESOPs must maintain under Rule 12(10), updated on each grant, vesting, exercise and lapse. We keep it current.

    Keep your ESOP register audit-ready and due-diligence-proof, every quarter. Patron Accounting maintains your Form SH-6 Register of Employee Stock Options in real time, recording each grant, vesting, exercise and forfeiture so investors and the ROC find a clean record.

    The SH-6 register is often the first document investors ask for in due diligence. It is the single source of truth for who holds what options and on what terms. A gap or a stale entry signals weak governance and can stall a funding round. Patron Accounting maintains the register as a managed, recurring service so it is always current and inspection-ready.

    Content is reviewed quarterly for accuracy.

    What Is the Form SH-6 Register

    Form SH-6 is the statutory Register of Employee Stock Options that a company must maintain under Rule 12(10) of the Companies (Share Capital and Debentures) Rules 2014. It records every option granted under Section 62(1)(b) and its lifecycle.

    The register is maintained, not filed: it is kept at the registered office and produced on inspection, audit or due diligence, rather than uploaded to the MCA portal as a routine e-form. Each entry is authenticated by the Company Secretary or an authorised person, and the register is preserved as a permanent governance record.

    Key Terms for SH-6 Register Administration:

    • Grant: the award of options to an employee, the first event recorded in SH-6.
    • Vesting: the point at which options become exercisable, recorded with its date.
    • Forfeiture or lapse: options lost on exit or non-exercise, recorded with any amount refunded.
    • Authentication: the Company Secretary or authorised signatory validating each entry.
    APL-05 SH-6 Register Administration
    Maintained under Rule 12(10)

    Who Must Maintain SH-6

    Every company that has issued employee stock options must maintain the SH-6 register, from the first grant onward.

    • Unlisted private and public companies that have approved an ESOP scheme.
    • Startups running ESOP pools for employees and advisors.
    • Listed companies, which also follow SEBI Share Based Employee Benefits norms.
    • Companies preparing for funding, audit or an acquisition due-diligence review.

    Statutory anchor: under Rule 12(10), a company that issues options under Section 62(1)(b) must maintain the Register of Employee Stock Options in Form SH-6 at its registered office, failing which Section 450 penalties apply to the company and every officer in default.

    Our SH-6 Administration Services

    ServiceWhat We Do
    Register Set-UpWe build your SH-6 register from the ESOP scheme, board and shareholder resolutions, and grant letters.
    Real-Time Event UpdatesWe record each grant, vesting, exercise, lapse and forfeiture as it happens, not at year-end.
    Reconciliation with Cap TableWe reconcile the register with the cap table and PAS-3 allotments so the numbers tie out.
    Due-Diligence PacksWe produce investor-ready register extracts and option summaries on demand.
    Resolution and Form LinkageWe link each entry to its board or shareholder resolution and any MGT-14 or PAS-3 filed.
    Annual Review and AuthenticationWe review the full register annually and have it authenticated by the Company Secretary.
    Our Process

    How We Maintain SH-6 in 6 Steps

    From building the base register to keeping it inspection-ready, we maintain SH-6 in real time so it never goes stale.

    Step 1

    Build the base register

    We capture the scheme, special resolution date and all live grants into Form SH-6.

    Scheme + SR date Live grants
    SH-6
    Register Built 01
    Step 2

    Record each grant

    We enter grantee, options granted, vesting schedule and exercise period for every new award.

    Grantee + options Vesting + exercise
    Grant Recorded 02
    Step 3

    Track vesting and exercise

    We update vesting dates, exercise dates, exercise price and shares arising on exercise.

    Vesting dates Shares arising
    Tracked 03
    Step 4

    Log lapses and forfeitures

    We record options lapsed, lock-in, and any amount forfeited or refunded.

    Lapses + lock-in Amount refunded
    Logged 04
    Step 5

    Reconcile and authenticate

    We tie the register to the cap table and PAS-3, then have the Company Secretary authenticate entries.

    Cap table + PAS-3 CS authenticated
    Reconciled 05
    Step 6

    Keep it inspection-ready

    We hold the register at the registered office and produce extracts for audit or due diligence.

    Registered office Extracts on demand
    Inspection-Ready 06

    Documents Checklist

    • ESOP scheme document and the special resolution approving it.
    • Board and shareholder resolutions for each grant.
    • Grant letters with grantee, options, vesting and exercise terms.
    • Exercise records, allotment details and PAS-3 references.
    • Forfeiture or lapse records on employee exits.
    • Cap table and any MGT-14 filings for reconciliation.

    Why investors check SH-6 first

    The SH-6 register is the cleanest proof of your option pool and dilution. A complete, authenticated register signals strong governance; a stale one raises questions that can delay or reprice a round.

    Common Challenges and How We Solve Them

    ChallengeImpactHow Patron Accounting Solves It
    Register updated only at year-end, not in real timeReconstruction scrambleWe record every grant, vesting and exercise event as it occurs.
    Register does not match the cap tableNumbers do not tie outWe reconcile SH-6 with the cap table and PAS-3 allotments each cycle.
    Due-diligence finds gaps or missing authenticationRound stallsWe complete and CS-authenticate the register and provide investor extracts.
    Confusion over filing vs maintainingIncorrect ROC filingWe maintain SH-6 at the registered office and keep it inspection-ready, no incorrect ROC filing.

    SH-6 Administration Fees

    Fee ComponentAmount
    Patron Accounting Professional FeesStarting from Rs 9,999 per year (Exl GST and Govt. Charges)
    Scope of the annual retainerRegister set-up, real-time event updates, cap-table reconciliation and annual authentication
    Due-diligence packs and historical clean-upQuoted on scope

    All fees and charges listed are indicative only and do not constitute a binding offer. Final amounts may vary depending on the volume of work and the complexity involved.

    Professional service charges for drafting, filing, and representation are separate from the statutory fees. The exact fee depends on the complexity of the case, disputed amount, and number of hearings required. Contact us for a detailed quote.

    Get a free SH-6 Register Administration consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

    Time Taken

    StageEstimated Timeline
    Initial register set-up from existing records3 to 5 working days
    Each event recorded once documents are receivedWithin 2 working days
    Annual review and authenticationScheduled ahead of the audit

    Real-time upkeep is the point, not a year-end scramble. Keeping the register current from the first grant means it is always ready when a funding round or audit calls for it at short notice.

    Key Benefits

    Why Use a Professional

    Always inspection-ready

    Always inspection-ready, so due diligence does not stall a funding round.

    Real-time accuracy

    Real-time accuracy, avoiding the year-end reconstruction scramble.

    No penalty exposure

    Section 450 penalty exposure removed through timely, authenticated entries.

    Numbers tie out

    Register reconciled with the cap table and allotment filings, so numbers tie out.

    Trusted by Startups and Growth Companies

    10,000+ Businesses | 4.9 Google Rating | 50,000+ Documents Processed | 15+ Years

    Patron Accounting LLP is a CA and CS firm with 15+ years maintaining statutory registers and secretarial records for Indian companies.

    With offices in Pune, Mumbai, Delhi and Gurugram, Patron Accounting serves businesses across India, both in-person and remotely.

    In-House vs Managed SH-6

    AspectIn-HousePatron Managed
    Update frequencyOften year-end onlyReal time, per event
    Cap-table matchFrequently driftsReconciled each cycle
    AuthenticationSometimes missedCS-authenticated
    Due-diligence readyLast-minute scrambleExtracts on demand
    Penalty riskSection 450 exposureManaged and avoided

    Related Services

    SH-6 administration sits within broader equity compliance. See our ESOP management and compliance services for scheme design, and issue of shares for allotment on exercise.

    For the wider company calendar, see private limited company compliance and secretarial audit. The register also feeds the ESOP perquisite tax computation at exercise, handled within our ESOP management and compliance services. See also the full ESOP services hub.

    Legal and Compliance Framework

    Governing provision: Section 62(1)(b) of the Companies Act 2013, read with Rule 12(10) of the Companies (Share Capital and Debentures) Rules 2014, requires the Register of Employee Stock Options in Form SH-6.

    Custody: the register is kept at the registered office or a Board-approved place and authenticated by the Company Secretary or an authorised person; it is maintained and produced on inspection, not filed as an MCA e-form.

    Listed companies: listed companies additionally comply with the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations 2021.

    Penalty: failure to maintain the register attracts Section 450 of the Companies Act, a penalty of Rs 10,000 on the company and every officer in default, with a further Rs 1,000 per day of continuing default, subject to statutory caps.

    Authoritative sources: the Ministry of Corporate Affairs (Companies Act, forms), the Companies Act and Rules, the ICSI (secretarial standards, registers), and SEBI (SBEB and Sweat Equity Regulations 2021).

    What is Form SH-6?

    Form SH-6 is the statutory Register of Employee Stock Options that a company must maintain under Rule 12(10) of the Companies (Share Capital and Debentures) Rules 2014. It records every option granted under Section 62(1)(b), along with vesting, exercise, lapse and forfeiture details, and is kept at the registered office and authenticated by the Company Secretary.

    Is maintaining the SH-6 register mandatory?

    Yes. Every company that has issued employee stock options must maintain the SH-6 register from the first grant. It is a mandatory statutory register under Rule 12(10). Failure to maintain it attracts a penalty under Section 450 of the Companies Act, namely Rs 10,000 on the company and every officer in default, plus Rs 1,000 per day of continuing default.

    SH-6 register ROC ko file karna padta hai?

    Nahi. SH-6 ek register hai jo registered office par maintain karna hota hai aur inspection ya due diligence par dikhana hota hai. Yeh MCA portal par routine e-form ki tarah file nahi hota. Entries Company Secretary authenticate karta hai.

    Where must the SH-6 register be kept?

    The SH-6 register must be kept at the registered office of the company, or at another place approved by the Board of Directors. It must be available for inspection and produced during audit or investor due diligence. Each entry is authenticated by the Company Secretary or an authorised person to make the record valid.

    What details does the SH-6 register record?

    The register records the grantee name, number of options granted, vesting date, exercise period, exercise date and price, number of shares arising on exercise, folio and lock-in, options lapsed, total options in force, any amount forfeited or refunded, and any variation in the scheme terms, each entry signed by the authorised person.

    What is the penalty for not maintaining SH-6?

    Because no specific punishment is prescribed, the residual penalty under Section 450 of the Companies Act 2013 applies: Rs 10,000 on the company and on every officer in default, with a further Rs 1,000 for each day the default continues, subject to statutory caps. ROCs have been actively adjudicating statutory-register defaults, so the exposure is real.

    Why do investors check SH-6 during due diligence?

    The SH-6 register is the authoritative record of the option pool and its dilution effect, so investors rely on it to verify who holds what options and on what terms. A complete, authenticated and reconciled register signals strong governance, while gaps or stale entries raise red flags that can delay, reprice or derail a funding round.

    Do listed companies also maintain SH-6?

    Yes. Listed companies maintain the SH-6 register under the Companies Act just like unlisted companies, and they additionally comply with the SEBI (Share Based Employee Benefits and Sweat Equity) Regulations 2021. The SEBI framework adds disclosure and administration requirements on top of the SH-6 register, but it does not replace the statutory register.

    Quick Answers

    • What is it? The statutory ESOP register, Form SH-6.
    • Under which rule? Rule 12(10), Share Capital and Debentures Rules.
    • Filed or maintained? Maintained at the registered office, not filed.
    • Who signs? The Company Secretary or authorised person.
    • Penalty? Section 450, Rs 10,000 plus Rs 1,000 per day.

    Why Timing Matters

    SH-6 must be updated in real time, on each grant, vesting and exercise, not reconstructed at year-end. A funding round or audit can demand the register at short notice, and a gap then is costly. Keep it current from the first grant, and Section 450 exposure never arises.

    Get Your SH-6 Register Managed

    The Form SH-6 register is small in size but large in consequence: it is mandatory under Rule 12(10), the first thing investors inspect, and a Section 450 liability if neglected.

    Patron Accounting LLP, a CA and CS firm with 15+ years of secretarial experience, maintains your SH-6 register in real time and keeps it authenticated, reconciled and due-diligence-ready year round.

    Book a Free Consultation - No Obligation.

    SH-6 Register Administration Across India

    In-person and remote register set-up, real-time updates, reconciliation and CS authentication for ESOP-issuing companies.

    We maintain SH-6 registers for companies nationwide, with offices in Pune, Mumbai, Delhi and Gurugram and remote support across India. The set-up, real-time updates, reconciliation and authentication is handled the same way wherever your registered office is.

    Content Created: 2 June 2026  |  Last Updated:  |  Next Review: 2 December 2026  |  Reviewed By: CA & CS Team, Patron Accounting LLP

    This page is reviewed every six months for amendments to Rule 12 or the Share Capital and Debentures Rules, MCA form or e-form changes, SEBI SBEB amendments, Section 450 penalty revisions, and new ROC adjudication trends on statutory registers (Tier 2 freshness).