---
title: "What an ROC search report is, who actually needs one, and what it should contain"
description: "An ROC search report is a professional's signed reading of a company's registry file. Here is the checklist it should cover, and where the ₹100 documents end and the fee begins."
author: "Pradeep Vanga"
published: 2026-09-11
updated: 2026-09-11
category: "Guide"
tags: ["roc-search-report", "due-diligence", "charges", "lending"]
canonical: https://entiva.in/blog/roc-search-report-india/
publisher: "Entiva"
---

# What an ROC search report is, who actually needs one, and what it should contain

Somebody has asked you for an ROC search report. Probably a bank, before it
sanctions a facility. Possibly a buyer, before it signs. And the first thing
you discovered is that the Companies Act does not contain the phrase.

That is because it is not a statutory document. It is a **practice** document:
a practising professional inspects the company's file at the Registrar of
Companies, reads it, and signs a report saying what is in it. There is no
prescribed form, which is why two search reports on the same company can differ
enormously in usefulness.

So it is worth knowing what a good one covers, and where the ₹100 of public
documents ends and the fee begins.

## Who actually asks for one, and why

**Lenders, mostly.** Banks and NBFCs commonly require a due diligence
certificate from a practising company secretary, chartered accountant or cost
accountant before sanctioning, a practice generally traced to an RBI circular
of 10 February 2009 dealing with lending under consortium and multiple banking
arrangements. Exactly what a given lender requires varies, so confirm it with
them rather than with a blog.

**Acquirers and investors**, as the first pass of legal diligence, before
anyone pays for the expensive kind.

**Counsel**, when a dispute turns on what the record showed on a particular
date.

Notice what unites them: all three are people who will have to **justify a
decision to somebody else later**. That is what they are buying. Not the data,
which is public, but a professional's name against a reading of it.

## What it should contain

There is no prescribed format, so here is the checklist a report ought to
cover. If one lands on your desk missing a row, that is the question to ask.

| Section | What it establishes | Where it comes from |
| --- | --- | --- |
| Identity | CIN, date of incorporation, registered office, current status | Master data |
| Constitution | Objects, and what the articles permit | MoA and AoA |
| Capital | Authorised, issued and paid-up, and allotments since | Annual return, PAS-3, SH-7 |
| Directors | Who they are now, and every change with dates | DIR-12, director master data |
| **Charges** | Every charge created, modified and satisfied, with holder, amount and date | CHG-1, CHG-4, index of charges |
| **Borrowing authority** | Whether the company had power to borrow and to charge assets | Special resolutions, MGT-14 |
| Filing compliance | Whether annual accounts and returns were filed, and when | AOC-4, MGT-7 |
| Status events | Strike off, CIRP, liquidation, amalgamation | Master data, the relevant filings |
| Observations | The professional's qualifications and caveats | The professional |

The two bolded rows are the ones a lender reads first, and often the only ones
it reads properly. The capital and shareholding rows come out of the annual
return, and where they matter,
[what the annual return shows about ownership](https://entiva.in/blog/who-owns-a-private-company-india/)
is worth reading first, because the shareholder list is an attachment rather
than a field and reports routinely miss it.

## The two rows that matter

**Charges, because ranking is everything.** A charge is a registered claim over
the company's assets. A lender about to take security wants to know what is
already secured, to whom, for how much, and whether anything shown as
outstanding has actually been repaid but never released. A search report that
lists open charges without commenting on whether they are genuinely live has
done half a job.

**Borrowing authority, because a company can lack it.** Under section 180 of
the Companies Act 2013, a board cannot, without a special resolution of the
shareholders, sell or dispose of "the whole or substantially the whole of the
undertaking", or borrow beyond the aggregate of the company's paid-up share
capital, free reserves and securities premium. So a lender needs to see that
the shareholders authorised the borrowing where the limits required it. That
authority reaches the registry as a filed resolution, and its absence is the
sort of thing that surfaces years later at the worst possible moment.

**And here is the part worth putting in the report.** Section 180 does not
apply to private companies at all: MCA's notification of 5 June 2015 exempts
them. But that exemption is conditional. A further notification in June 2017
made the exemptions available only to "a private company which has not
committed a default in filing its financial statements under section 137 …
or annual return under section 92 … with the Registrar".

Read those together and something useful falls out. **A private company that
has fallen behind on its AOC-4 or MGT-7 loses its section 180 exemption**, and
borrowing it treated as a board matter may retrospectively have needed a
special resolution. That is a direct, checkable link between the filing-history
row of a search report and the borrowing-authority row, and it is exactly the
kind of thing a report that lists both without connecting them will miss.

## What the fee is actually for

Here is the arithmetic nobody puts in writing.

The registry charges **₹100 per company** for View Public Documents access, and
that single fee covers every form the registry holds for that company, across
all eight categories and every year. Firms advertising search reports publicly
quote from roughly **₹1,299 to ₹2,499** for one company, more for a large or
long-lived file.

The gap is not the data. The data is the same data. The gap is:

- **Time.** The portal serves one document category at a time, with its own
  captcha, a five-document selection cap, and a three-hour clock that starts
  the moment you download the first file. Assembling a complete set for one
  company is a genuine afternoon. We have written up
  [the full route and its constraints](https://entiva.in/blog/how-to-download-mca-documents/).
- **Reading.** Knowing that a charge shown as open may be dead, that a
  resignation can predate the filing that records it, and that a missing year
  is a finding rather than a gap.
- **The signature.** A professional putting their name to a conclusion, which
  is what makes the report usable by somebody who has to defend a decision.

**If your lender wants the signature, documents will not substitute for it.**
That is the honest answer, and anyone who tells you otherwise is selling
something. If what you actually need is the underlying file, to read yourself
or to hand to the professional preparing the report, then the ₹100 route is the
whole of it.

## What a search report is not

**It is not an audit.** Nobody has verified that the filed accounts are
correct. The report says what was filed.

**It is not a litigation search.** Cases against the company sit with courts
and tribunals, not with the ROC. A separate exercise, and often the more
important one.

**It is not a title search.** Whether the company owns the land it says it owns
is a question for the sub-registrar and the local land records.

**It is not a valuation**, and it is not a credit opinion.

**And it is point-in-time.** A search report is accurate as at the date of
inspection and starts decaying immediately. Filings lag, statuses change, and a
report three months old is a historical document. If the transaction has moved
slowly, ask for a bring-down search before signing rather than relying on the
first one.

## If you are commissioning one

1. **Ask what the requester actually needs.** A lender's format is not an
   acquirer's. Get it in writing before anyone starts.
2. **Give the professional the CIN**, not the trading name. Group companies
   with near-identical names are the commonest cause of a report on the wrong
   entity. [Reading the CIN](https://entiva.in/blog/how-to-read-a-cin-number/) takes a minute,
   and so does the
   [free two-minute check on whether the entity is real and active](https://entiva.in/blog/how-to-check-if-a-company-is-real/),
   which is worth doing before you commission anything.
3. **Say how many years back.** "All available" and "last three financial
   years" are very different jobs and very different prices.
4. **Ask for the underlying documents with the report.** You paid for the
   inspection; you should hold the file, not just the summary. If it ever
   becomes contentious, the document is the evidence and the report is an
   opinion about it.
5. **Check the charges section names the holders and the amounts**, and says
   which are satisfied.
6. **Note the inspection date on the face of it.**

## If you are preparing one

The retrieval is the bulk of the work and the least interesting part of it.
Pull all eight categories, extract the archives, index what you have, and note
what is absent, because an empty charge category and an unretrieved charge
category look identical in a folder and mean opposite things.

That distinction is why our own retrieval reports a gap as a gap and gives you
a record of every file it delivers: if you are going to sign a report about
what the record contains, you want to be able to prove later what the record
sent you.
[What a full retrieval covers](https://entiva.in/what-you-can-find/) is the raw material, not
the report itself. The reading and the signature are still yours.

*Written by the Entiva team, who retrieve MCA filings for a living. Not legal
advice, and not a substitute for a professional's certificate where one is
required.*

## Frequently asked

### What is an ROC search report?

A report prepared by a practising company secretary, chartered accountant or advocate after inspecting a company's file at the Registrar of Companies. It sets out the company's identity, capital, directors, registered charges and filing compliance, with the professional's observations. It is a practice document required by lenders and acquirers, not a form prescribed by the Companies Act.

### How much does an ROC search report cost in India?

Firms advertising the service publicly quote from roughly ₹1,299 to ₹2,499 for a single company, and more for complex or older files. The underlying registry inspection fee is ₹100 per company. The difference is the professional's time and signature, which is usually the part the bank is buying.

### Why do banks ask for an ROC search report?

Chiefly to confirm what is already charged over the borrower's assets, and to confirm that the company had the authority to borrow and to create the charge. Lenders commonly require a due diligence certificate from a practising professional, a practice associated with RBI's 2009 circular on multiple banking and consortium arrangements.

## Related reading

- [How to download a company's documents from the MCA portal, and what it actually costs you](https://entiva.in/blog/how-to-download-mca-documents/): The MCA charges ₹100 to see a company's filings. Here is the full route through View Public Documents, the four limits nobody warns you about, and when it is worth it.
- [Who owns this company? What the annual return shows about shareholding, and what it hides](https://entiva.in/blog/who-owns-a-private-company-india/): Shareholding in an Indian private company is public, once a year, in an attachment to the annual return. Here is where to find it and the three things it will not tell you.
- [How to check if a company is real before you give them money](https://entiva.in/blog/how-to-check-if-a-company-is-real/): A quarter of the entities on India's companies register no longer legally exist. Here is how to check the one in front of you, free, in about two minutes.

_Published by Entiva (https://entiva.in/), which retrieves documents from the Ministry of Corporate Affairs' View Public Documents service on a customer's behalf. Entiva is not affiliated with the Ministry of Corporate Affairs and does not resell another provider's database. Free lookups use MCA company master data._