SBO Register and BEN-3 Maintenance (Section 90)

BEN-3 maintenance from Patron Accounting keeps this register accurate and audit-ready year-round, recording each SBO’s details, updating on any change, linking to the BEN-1 declarations and BEN-2 filings, and keeping the register inspection-ready. It pairs with our SBO identification and BEN-2 filing service. Our team has supported 10,000+ businesses since 2009.

BEN-3 is the ongoing register-upkeep companion to the per-event SBO declaration and BEN-2 filing: the register is maintained by the company and is not filed with the ROC, while the BEN-2 return is. The register is verified within a secretarial audit, and where the ownership chain includes a foreign holder it links to FDI compliance.

Every reporting company that has identified, or should identify, a significant beneficial owner must maintain the BEN-3 register, alongside the BEN-1 declarations and BEN-2 filings.

• Reporting companies: Any company required to comply with Section 90 and identify an SBO.
• On receiving BEN-1: Once an SBO declares in BEN-1, the details are entered in the BEN-3 register.
• On any change: The register is updated whenever beneficial ownership is acquired, changes or ceases.
• Audit and inspection: Kept current so it is ready for a member inspection, an audit or a due diligence.
• LLPs: LLPs maintain a parallel register in Form LLP BEN-3 under the LLP SBO rules.

This register upkeep pairs with our SBO identification and BEN-2 filing service, which handles the per-event declaration and ROC return.

• Name, address and contact details of each significant beneficial owner.
• Date of birth, parent or spouse name, occupation and nationality.
• PAN or UIN, and passport details for foreign nationals.
• Nature and extent of the significant beneficial interest.
• Dates of the declaration, register entry and any cessation.
• Date of the related BEN-2 filing with the ROC.

Need the full format? We set up and maintain the register in the prescribed BEN-3 format for you.

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.

The per-event SBO identification and BEN-2 filing is a separate service and is charged separately where a new declaration or change has to be reported to the ROC. Contact us for a detailed quote.

Get a free BEN-3 Maintenance consultation - Call +91 945 945 6700 or WhatsApp us. No-obligation assessment.

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

"We had filed BEN-2 but never kept the BEN-3 register. Patron set it up and now maintains it, so our SBO records are audit-ready." - Director, technology company, Bengaluru.

"Patron keeps our BEN-3 register updated whenever our ownership changes, on a simple yearly basis." - Founder, services company, Pune.

Trusted by leading brands including Hyundai, Asian Paints and Bridgestone for accounting and compliance support.

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

BEN-3 maintenance pairs with the SBO declaration and BEN-2 filing and the wider register and compliance work. Patron handles all of it.

• Secretarial Audit which verifies the SBO and statutory registers.
• FDI Compliance where the ownership chain includes a foreign holder.
• Private Limited Company Compliance for the wider annual compliance.
• Compliance Calendar to track SBO and other due dates.
• Pvt and LLP Compliance for ongoing entity compliance.

The per-event SBO identification and BEN-2 filing is handled by our SBO declaration and BEN-2 filing service, which this register upkeep pairs with.

The register: Section 90(2) of the Companies Act, 2013 read with Rule 5(1) of the Companies (Significant Beneficial Owners) Rules requires every reporting company to maintain a register of significant beneficial owners in Form BEN-3.

Not a filing: BEN-3 is a register kept by the company and is not filed with the Registrar, unlike the BEN-2 return; the company records each SBO and updates the register on any change in beneficial ownership.

Contents: The register records, for each significant beneficial owner, the name, address and contact, date of birth, parent or spouse name, occupation, nationality, PAN or UIN, passport for foreign nationals, status, and the dates of the declaration, cessation, register entry and BEN-2 filing, with the nature and extent of the interest.

Inspection: Under Section 90(3) and Rule 5(2), the register is open to inspection by any member during business hours, for not less than 2 hours on every working day as the Board decides, on payment of a fee not exceeding 50 rupees for each inspection.

Refer to the MCA portal for forms and to Section 90 on IndiaCode for the bare provision.

The BEN-3 register is the part companies most often forget. Many file BEN-2 once and never maintain the register, leaving a gap that an audit, a secretarial review or a due diligence will find. Because the SBO regime is penalty-bearing, an incomplete or missing register is a real exposure. A simple yearly upkeep keeps the register complete, updated on change and ready whenever it is needed.

Keep your register current - Call +91 945 945 6700 or WhatsApp us. We respond within 2 hours.

The BEN-3 register is the company’s standing record of its significant beneficial owners under Section 90(2) and Rule 5(1): maintained, not filed, recording the prescribed details of each SBO, updated on every change, and open to member inspection.

Keeping it current and audit-ready is a small but important discipline that pairs with the SBO declaration and BEN-2 filing. Patron Accounting, with qualified CAs and CSs and offices in Pune, Mumbai, Delhi and Gurugram, maintains your BEN-3 register on a simple annual upkeep.

10,000+ Businesses | 4.9 Rating | 50,000+ Documents Filed | 15+ Years. Book a free consultation today.