Transparent ownership, robust governance, and full ROC compliance.
BEN Forms (Significant Beneficial Ownership – SBO Compliance).
This is a mandatory disclosure compliance under the Companies Act, 2013, where companies must identify and report individuals holding significant beneficial ownership (SBO).
Why It Matters
The Companies Act, 2013 (Section 90) mandates all companies to identify and declare their Significant Beneficial Owners (SBOs) — individuals who hold 25% or more beneficial interest in the company (directly or indirectly).
The compliance is filed through BEN forms:
- BEN-1 ? Declaration by Significant Beneficial Owner to the company
- BEN-2 ? Company's return of SBOs to ROC
- BEN-3 ? Register of SBOs maintained by the company
- BEN-4 ? Notice by company to suspected SBOs
Non-compliance consequences:
- Heavy penalties on company & every officer in default
- Continuous penalties for failure to report SBOs
- Regulatory action for non-disclosure of beneficial ownership
Our Services
SBO Identification - Assess shareholding & voting rights to identify SBOs
Drafting & Collection of BEN-1 - Assist SBOs in filing declaration with company
Preparation & Filing of BEN-2 - File return of SBOs with ROC
Maintaining BEN-3 Register - Statutory register for SBOs as per Companies Act
Issuance of BEN-4 Notices - Draft & serve notices to suspected SBOs
End-to-End Compliance - Advisory + drafting + filing + ROC approvals
Why Choose FinnovateAI?
CA & CS-Led Team - Expertise in corporate ownership & ROC compliance
End-to-End Execution - From identifying SBOs ? drafting ? filing ? register maintenance
Regulatory Assurance - Ensure full compliance with Section 90 of Companies Act, 2013
Confidential & Accurate - Sensitive ownership information handled with care
Penalty Avoidance - Timely filings to avoid heavy fines and legal exposure
Our Process
Ownership Analysis - Review shareholding, rights & indirect holdings
SBO Identification - Determine individuals qualifying as SBOs
Collect Declarations - Draft & assist in obtaining BEN-1 from SBOs
ROC Filing (BEN-2) - File company's return of SBOs with MCA
Register Maintenance - Update & maintain BEN-3 at the registered office
Ongoing Support - Issue BEN-4 notices and update ROC filings as changes occur
Who Needs It?
Private & Public Companies with complex shareholding patterns
Startups with foreign or layered investors
Family-owned businesses with beneficial ownership structures
Investor-backed companies needing transparent disclosures for compliance
MNC subsidiaries with cross-border shareholding