What a charge is, and what CHG-1 does
A charge is security a company gives over its property for a loan: a hypothecation of stock and receivables, a mortgage of land or building, a charge over plant and machinery, or a lien over a deposit.
CHG-1 is the form in which the company registers the particulars of that charge with the Registrar of Companies, signed by the company and the charge-holder, with the instrument creating the charge. Section 77 of the Companies Act, 2013 makes it the company's duty, not the bank's. On registration the Registrar issues a certificate of registration of the charge, and the charge appears against the company on the MCA record, where anyone doing diligence can see it.
That visibility is the point of the whole exercise. A charge nobody can see is a charge the next lender does not know about, which is why the law attaches real consequences to not registering it.
The 30 day rule and the two extensions
Register within 30 days of the date of creation of the charge. That is the rule, and the date of creation is the date of the security document, not the date the money reached your account.
For a charge created on or after 2 November 2018, section 77 then gives two extensions, and only two:
| Stage | Period | What you pay |
|---|---|---|
| On time | Within 30 days of creation | Normal fee only |
| First extension | The Registrar may allow registration within 60 days of creation | Normal fee plus an additional fee |
| Second extension | If not registered in that 60 days, the Registrar may allow a further period of 60 days | The above plus an ad valorem fee |
For a charge created before 2 November 2018 the equivalent window was 300 days from creation, which matters now only for very old unregistered security.
The outer limit is 120 days
Add it up: 30 days, then up to 60 days from creation, then a further 60 days. The outer limit is 120 days from the date the charge was created.
We are deliberate about what we say next, because the SERP is not. Once that window has gone, the charge cannot be brought onto the record by simply filing CHG-1 late. In practice the security is re-executed so that a fresh charge, with a fresh date of creation, can be registered inside time, and the lender is usually the party pushing for that. Whether any other route remains open in your case is a question we check on the current position rather than answer from a template.
The practical lesson is smaller than the law: put the CHG-1 date in the diary on the day the security document is signed.
What it costs to file late
Two separate amounts, and it is worth keeping them apart.
Normal fee. The standard Table of Fees amount, set by the company's authorised share capital:
| Authorised share capital | Normal fee |
|---|---|
| Less than ₹1,00,000 | ₹200 |
| ₹1,00,000 to less than ₹5,00,000 | ₹300 |
| ₹5,00,000 to less than ₹25,00,000 | ₹400 |
| ₹25,00,000 to less than ₹1,00,00,000 | ₹500 |
| ₹1,00,00,000 and above | ₹600 |
A company not having share capital pays ₹200.
Delay fees. Charges created on or after 2 November 2018 carry their own delay regime, which is not the general multiple that applies to other ROC forms:
| Company | Multiple of the normal fee on a delayed filing | Ad valorem fee, where the delay reaches the second window |
|---|---|---|
| Small company or one person company | 3 times | 0.025% of the amount secured by the charge, subject to a maximum of ₹1,00,000 |
| Any other company | 6 times | 0.05% of the amount secured by the charge, subject to a maximum of ₹5,00,000 |
We state the rates precisely and the day bands loosely, on purpose: the published sources disagree about exactly which day the ad valorem fee starts, so we compute the payable amount on the MCA portal for your filing date and show you the working before anything is paid. Anyone who quotes you a figure without the date of creation and the amount secured is guessing.
How the ad valorem fee works
The multiple applies to a small fee. The ad valorem fee applies to your loan.
A company that is not a small company, with a ₹4 crore facility, filing late enough to reach the second window, is looking at 0.05% of ₹4,00,00,000, which is ₹20,000, on top of six times the normal fee. On a ₹40 crore facility the same percentage reaches the ₹5,00,000 cap. That is the difference between a clerical delay and a real number, and it is why the date of the security document matters more than any other date in this process.
Why the lender insists, and what happens if nobody files
Section 77(3) is the answer. A charge created by a company is not taken into account by the liquidator or by any other creditor unless it is duly registered and a certificate of registration is issued.
So an unregistered charge leaves the lender holding security that may count for nothing exactly when it matters: in a liquidation, or against a competing creditor. Section 77(4) preserves the borrower's obligation to repay, so the debt survives even when the security does not. The bank loses the priority; you still owe the money.
Two further points that change the conversation with your lender:
- The lender can file it itself. Under section 78, where the company fails to register within the 30 days, the person in whose favour the charge is created may apply to the Registrar. The Registrar gives the company 14 days' notice to register it or show cause.
- And recover the cost from you. Section 78 entitles that person to recover from the company the fees and additional fees paid to the Registrar. Your delay becomes your cost either way.
If your loan documents already say the company will register the charge and indemnify the lender for the cost of doing so, that clause is drafted against this section.
CHG-1 or CHG-9: which form
| Situation | Form |
|---|---|
| Charge created or modified on the company's property, in favour of a bank, a financial institution or any other lender | CHG-1 |
| Charge created or modified by way of an issue of debentures | CHG-9 |
Both sit in the same fee regime, with the same additional and ad valorem structure. If you are issuing debentures, the charge filing is one step inside a larger process: see issue of debentures and compulsorily convertible debentures.
Modification of a charge
A modification is registered the same way, in the same form, on the same clock. The change in the sanctioned amount when a limit is enhanced, a change in the security, a change in the terms, or a substitution of the charge-holder on an assignment of the loan all need to reach the Registrar.
This is the filing most often missed, because nobody treats an enhancement as a new event. It is one: the 30 days run again from the date of the document that modified the charge.
Removing a charge: CHG-4 satisfaction
When the loan is repaid, the charge has to come off the record, and it does not come off by itself.
Under section 82, the company gives intimation to the Registrar of the payment or satisfaction in full of a registered charge within 30 days of the payment or satisfaction. The form is CHG-4. The Registrar may, on an application by the company or the charge-holder, allow the intimation to be made within 300 days on payment of an additional fee.
On receiving the intimation, the Registrar sends a notice to the charge-holder to show cause within a period of not more than 14 days as to why satisfaction should not be recorded. If no cause is shown, a memorandum of satisfaction is entered in the register of charges and the company is informed.
Get the no dues certificate from the lender on the day you close the loan, because the satisfaction filing needs it. A stale charge on the MCA record is the single most common finding in diligence on a small company, and it blocks three things: a new lender's comfort, a strike-off, and an application for dormant status, where an outstanding secured loan is a disqualifying condition. See due diligence, closure of a private limited company and dormant company status.
The penalty under section 86
Section 86(1), as substituted by the Companies (Amendment) Act, 2020 with effect from 21 December 2020: if a company is in default in complying with any provision of the charges chapter, the company is liable to a penalty of ₹5,00,000 and every officer of the company who is in default is liable to a penalty of ₹50,000.
If you have read that the penalty is a fine of ₹1,00,000 to ₹10,00,000 with imprisonment of up to six months for officers, that was the position before 21 December 2020. It is a monetary penalty now, and it is still large enough to make the 30 days worth diarising.
Section 86(2) is separate and more serious: wilfully furnishing false or incorrect information, or knowingly suppressing material information required to be registered under section 77, attracts action under section 447, the fraud provision.
Penalties and fees are different things. The additional and ad valorem fees are what the MCA charges to accept a late form. The section 86 penalty is adjudicated.
Documents we need to file CHG-1
- The instrument creating the charge: hypothecation deed, mortgage deed, deed of assignment or equivalent
- The sanction letter and the loan agreement
- The date of creation of the charge, and the amount secured
- Details of the charge-holder, with its address and the branch
- Description of the property or assets charged
- Board resolution authorising the borrowing and the creation of the security
- Where the borrowing needs it, the members' resolution under section 180
- Particulars of any earlier charge on the same property, and the no objection or priority arrangement
- The company's CIN and the DSC of the authorised signatory, and the charge-holder's signature on the form
Government fees for CHG-1
| Item | Government fee |
|---|---|
| CHG-1 or CHG-9, normal fee | ₹200 to ₹600 by authorised capital; ₹200 for a company without share capital |
| Delayed filing, multiple of the normal fee | 3 times for a small company or OPC, 6 times for any other company |
| Ad valorem fee, where the delay reaches the second window | 0.025% of the amount secured, capped at ₹1,00,000, for a small company or OPC; 0.05%, capped at ₹5,00,000, for any other company |
| CHG-4 satisfaction, filed within 30 days | Normal fee |
| CHG-4 filed late, up to 300 days with the Registrar's permission | Normal fee plus an additional fee, computed at filing |
| Stamp duty on the security document | State law, paid on the instrument, not an MCA fee |
A small company is one with paid-up capital of ₹10 crore or less and turnover of ₹100 crore or less, under the threshold notified on 1 December 2025. Which side of that line you are on changes the multiple and the ad valorem rate, so it is worth confirming before the fee is computed.
Our fee for charge filings
Fee on quote after a free review. The review takes five minutes for a charge created last week and rather longer for one created eight months ago.
| Item | Amount |
|---|---|
| Professional fee: CHG-1 or CHG-9, creation or modification | Fee on quote after a free review |
| Professional fee: CHG-4, satisfaction of charge | Fee on quote |
| Government fees | As in the table above, at actuals, computed on the MCA portal for your filing date |
| Related work, if the borrowing needs it: increasing authorised capital | ₹1,999. See increase in authorised capital |
Professional fees exclude GST at 18%. Government fees, where they apply, are paid at actuals to the department and are shown separately. Fees verified on 27 September 2026.
How we file it
- Fix the date of creation. We read the security document and establish the date the clock started, which is the single fact everything else depends on.
- Compute the position. Deadline, or the fee for your filing date, including the ad valorem amount where it applies, with the working shown.
- Check the authority. Board resolution for the borrowing and the security, and the members' resolution under section 180 where the limits require it.
- Prepare CHG-1. Particulars of the charge, the charge-holder and the property, reconciled to the instrument.
- Get the charge-holder's signature. The form is signed by the company and the charge-holder, so the bank's turnaround is part of the timeline.
- File and follow through. Upload with the DSC, then the certificate of registration, and we update the company's own register of charges.
For a satisfaction, the sequence starts with the lender's no dues certificate and ends with the memorandum of satisfaction on the record.
Five mistakes we see
- Counting from disbursement. The 30 days run from the date the charge was created, which is the date of the security document.
- Treating an enhancement as nothing. A modification of the charge is its own filing with its own 30 days.
- Waiting for the bank. The duty under section 77 is the company's. Under section 78 the lender can file and recover the cost from you.
- Leaving a repaid loan on the record. CHG-4 within 30 days. A stale charge blocks diligence, a strike-off and dormant status.
- Quoting the old penalty. Section 86 has been ₹5,00,000 on the company and ₹50,000 on each officer in default since 21 December 2020.
Related: annual ROC filing · private limited company · project report · CMA data · LEI registration