Form CHG-4 in ROC Compliance: Filing Process & Legal Requirements

Introduction

Form CHG-4 in ROC compliance is an important event-based filing under the Companies Act, 2013. Whenever a company fully repays a loan or satisfies a registered charge created on its assets, it must notify the Registrar of Companies (ROC) through Form CHG-4. Filing this form ensures that MCA records accurately reflect the company’s financial obligations and that satisfied charges are removed from the register of charges. As per Section 82 of the Companies Act, 2013, a company must intimate the ROC regarding the satisfaction of a registered charge within the prescribed period.

This blog is a complete guide to Form CHG-4 filing for satisfaction of charge under ROC compliance requirements.

What is Form CHG-4 in ROC Compliance?

Form CHG-4 in ROC compliance is an e-form used to notify the Registrar of Companies that a registered charge has been fully paid or satisfied. A charge is a security interest created on the assets of a company in favour of a lender, such as a bank or financial institution.

When the underlying debt is fully repaid, the company must file Form CHG-4 in ROC compliance so that the charge can be marked as satisfied in MCA records. This filing helps ensure transparency and prevents satisfied charges from continuing to appear as active obligations.

What is a Charge Under the Companies Act, 2013?

Before understanding Form CHG-4 in ROC compliance, it is important to understand the meaning of a charge.

A charge refers to an interest or lien created on the property or assets of a company as security for repayment of a loan or financial obligation. Under Section 77 of the Companies Act, 2013, companies are required to register charges with the ROC.

Common examples of charges include:

• Mortgage on land and buildings
• Hypothecation of machinery and equipment
• Charge on inventory and stock
• Charge on receivables
• Security interests created in favour of banks and financial institutions

Once the secured obligation is discharged, Form CHG-4 in ROC compliance is used to intimate the satisfaction of that charge.

Why is Form CHG-4 in ROC Compliance Important?

Filing Form CHG-4 in ROC compliance is important because it ensures that the company’s charge records remain accurate and up to date.

Some key benefits include:

1. Maintains Accurate MCA Records: The MCA database should correctly reflect whether a charge is active or satisfied.

2. Facilitates Future Borrowings: Banks and lenders review charge records before granting new loans.

3. Enhances Corporate Transparency: Updated records improve trust among investors, creditors, and stakeholders.

4. Supports Due Diligence Activities: During mergers, acquisitions, and investments, charge records are carefully examined.

5. Strengthens Regulatory Compliance: Timely filing of Form CHG-4 in ROC compliance demonstrates adherence to statutory requirements.

Legal Provisions Governing Form CHG-4 in ROC Compliance

Section 82 of the Companies Act, 2013

Section 82 requires a company to intimate the Registrar regarding the payment or satisfaction in full of any registered charge. The intimation must be filed in the prescribed form within 30 days from the date of satisfaction.

Rule 8 of the Companies (Registration of Charges) Rules, 2014

Rule 8 specifically prescribes Form CHG-4 in ROC compliance as the form for reporting satisfaction of charge.

Role of the Registrar of Companies (ROC)

The ROC is the statutory authority responsible for:

• Examining Form CHG-4 filings
• Verifying satisfaction details
• Recording the memorandum of satisfaction

Updating the register of charges maintained under the Companies Act, 2013

When is Form CHG-4 in ROC Compliance Required to be Filed?

A company should file Form CHG-4 in ROC compliance whenever a registered charge has been fully satisfied.

Common situations include:

Repayment of Term Loans: When the entire loan amount and applicable dues have been paid.

Satisfaction of Mortgage: When a mortgage created on company property has been discharged.

Closure of Cash Credit or Overdraft Facilities: When secured working capital facilities have been settled.

Release of Security Interest: When the lender releases its claim over the secured assets.

Who Can File Form CHG-4 in ROC Compliance?

As per Rule 8(1) of the Companies (Registration of Charges) Rules, 2014, Form CHG-4 in ROC compliance may be filed by:

• The company, or
• The charge holder

The form is generally signed by a Director, Company Secretary, Chief Financial Officer, or another authorized signatory using a valid Digital Signature Certificate (DSC).

The Companies (Registration of Charges) Amendment Rules, 2018 also recognise the ability of the charge holder to file Form CHG-4 in ROC compliance for reporting satisfaction of charge.

What is the Due Date for Filing Form CHG-4 in ROC Compliance?

Under Section 82(1) of the Companies Act, 2013, a company is required to intimate the Registrar regarding the satisfaction of a registered charge within 30 days from the date of payment or satisfaction of the charge.

Further, Rule 8(1) of the Companies (Registration of Charges) Rules, 2014, as amended, permits filing of Form CHG-4 in ROC compliance within 300 days from the date of satisfaction, subject to payment of prescribed fees.

Therefore, companies should ideally complete Form CHG-4 in ROC compliance within the initial 30-day period to ensure timely updating of MCA records and avoid additional compliance requirements.

Documents Required for Form CHG-4 in ROC Compliance

The following documents are generally required:

No Objection Certificate (NOC): Confirmation from the lender that all dues have been cleared.

Satisfaction Letter: A document confirming discharge of the secured obligation.

Loan Closure Certificate: Evidence of complete repayment.

Board Resolution (Where Applicable): Authorization for filing the form.

Information Required in Form CHG-4 in ROC Compliance

While filing Form CHG-4 in ROC compliance, companies are generally required to provide:

• Corporate Identification Number (CIN)
• Company name registration
• Charge Identification Number (Charge ID)
• Charge holder details
• Date of satisfaction
• Amount secured by the charge
• Particulars relating to repayment

Step-by-Step Process for Filing Form CHG-4 in ROC Compliance

Step 1: Verify Satisfaction of Charge

Confirm that the debt secured by the charge has been fully discharged.

Step 2: Obtain Lender Confirmation

Collect NOC, satisfaction letter, and loan closure documents.

Step 3: Prepare Form CHG-4

Enter all required company and charge details.

Step 4: Attach Supporting Documents

Upload all relevant supporting documents.

Step 5: Affix DSC

Digitally sign the form through an authorized signatory.

Step 6: Submit on MCA Portal

Upload the form and pay the prescribed filing fee.

Form CHG-1 vs Form CHG-4 in ROC Compliance

Consequences of Non-Filing of Form CHG-4 in ROC Compliance

Failure to file Form CHG-4 in ROC compliance can result in several practical challenges:

• The charge may continue to appear as active in MCA records.
• Future lenders may treat the company’s assets as encumbered.
• Due diligence processes may become more complicated.
• Corporate records may not accurately reflect the company’s financial position.

Therefore, companies should ensure timely filing of Form CHG-4 in ROC compliance immediately after satisfying a registered charge.

What Happens After Filing Form CHG-4 in ROC Compliance?

After submission of Form CHG-4 in ROC compliance, the Registrar of Companies examines the details and supporting documents submitted by the company or charge holder.

Where required, the Registrar may issue notice to the charge holder seeking confirmation regarding satisfaction of the charge. After verification, the Registrar records a memorandum of satisfaction in the register of charges maintained under the Companies Act, 2013.

Upon successful registration of satisfaction, the ROC issues Form CHG-5 (Certificate of Registration of Satisfaction of Charge) under Rule 8(2) of the Companies (Registration of Charges) Rules, 2014.

Form CHG-5 serves as official evidence that the satisfaction of charge has been recorded and that the charge no longer remains outstanding in MCA records.

What is Form CHG-5 and Why is it Important?

After approval of Form CHG-4 in ROC compliance, the Registrar issues Form CHG-5, known as the Certificate of Registration of Satisfaction of Charge.

Form CHG-5 is important because it:

• Confirms that the ROC has recorded the satisfaction of charge.
• Acts as official evidence of discharge of the secured obligation.
• Helps companies maintain accurate statutory records.
• Supports future financing and due diligence activities.
• Provides documentary proof that the charge no longer exists in MCA records.

Companies should preserve Form CHG-5 along with their statutory records for future reference.

Simplify Form CHG-4 Filing with Expert Support

Filing Form CHG-4 in ROC compliance is essential for updating MCA records once a company has fully repaid a secured loan or satisfied a charge. However, errors in documentation, incorrect charge details, or delayed filing can lead to unnecessary compliance issues.

Ebizfiling makes the process simple with end-to-end assistance, including document verification, charge satisfaction review, form preparation, MCA filing, and expert compliance guidance. Our team ensures that your filing is completed accurately, efficiently, and in accordance with the Companies Act, 2013.

Need help filing Form CHG-4? Connect with Ebizfiling today and ensure stress-free ROC compliance with expert support at every step.

Conclusion

Form CHG-4 in ROC compliance is a crucial filing requirement under Section 82 of the Companies Act, 2013 for reporting the satisfaction of a registered charge. Whether a company repays a term loan, discharges a mortgage, or settles another secured borrowing, timely filing of Form CHG-4 in ROC compliance ensures that MCA records remain accurate and up to date.

By completing Form CHG-4 in ROC compliance within the prescribed timeline, companies can maintain transparent corporate records, facilitate future borrowing, strengthen regulatory compliance, and avoid complications during due diligence exercises. Once the filing is approved, the ROC issues Form CHG-5 as official confirmation of satisfaction of charge, providing further assurance that the company’s charge records have been properly updated.

Frequently Asked Questions