MCA index of charges: how to check and read it

The MCA index of charges is a public summary of security interests registered against a company. Search the company in MCA’s Master Data Services and open Index of Charges to see the charge holder, secured amount and dates of creation, modification and satisfaction. An empty satisfaction date means no satisfaction is recorded there. It does not tell you how much the company still owes.

If you are owed money or buying an asset, the index helps you identify claims to investigate. The charge filings and underlying instruments give you more detail than the index.

What is a charge on a company?

A company borrows. The lender wants security, so the company gives the lender a claim over something: the factory, the machinery, the stock, the book debts, sometimes just about everything it owns. That claim is a charge.

The company then has to tell the Registrar of Companies about it, and the Registrar records it in a public register. Anyone can read that register.

Two consequences follow, and they are the whole of the practical point:

• A registered charge tells the world that the asset is spoken for.
• Registered security can affect recovery from the charged asset. If you hold an unpaid invoice without security, check what assets are charged and seek advice on priority in the relevant proceeding.

How to check the MCA index of charges

On the MCA portal, search a company under Master Data Services and the result comes back on three tabs. The middle one is the Index of Charges. It works from a company’s CIN or an LLP’s LLPIN, and MCA serves it without a fee. If you need to identify the right company first, use the free company lookup. To get the available charge filings, see how the document order works.

Two things about it are worth fixing in your head before you read one, because both catch people out.

It is not one of the eight document categories you pay for. Those are the View Public Documents sets, and charge instruments sit in one of them. The Index of Charges is the free summary view, on a different part of the portal. If you bought document access and are looking for the index in what came back, you are looking in the wrong place; if you only want the index, you do not need to buy those documents. Our guide to downloading MCA documents covers the paid route.

The public tab is currently free to view. Section 81(2) and rule 7(2) describe inspection on payment of a prescribed fee. The portal currently serves this summary without asking you to buy document access.

That tab is not a convenience feature. It is the statutory register. Rule 7 of the Companies (Registration of Charges) Rules 2014 provides that the particulars of charges maintained on the MCA portal “shall be deemed to be the register of charges for the purposes of Section 81 of the Act”, and section 81 itself says:

(2) A register kept in pursuance of this section shall be open to inspection by any person on payment of such fees as may be prescribed for each inspection.

By any person. You do not need a reason, a relationship, or permission.

There is a harder reason to look than entitlement, and it is section 80:

Where any charge on any property or assets of a company or any of its undertakings is registered under section 77, any person acquiring such property, assets, undertakings or part thereof or any share or interest therein shall be deemed to have notice of the charge from the date of such registration.

Deemed to have notice. Section 80 addresses a person acquiring charged property, an undertaking or an interest in it. Check the registration and the underlying instrument before buying an asset that may be subject to a charge.

Register of charges vs index of charges

The two names get used interchangeably, and they are two different registers. The index of charges is the Registrar’s register under section 81, the tab on the MCA portal. The register of charges in the narrower sense is the one the company keeps itself, and it holds more. Under section 85 every company must keep its own register of charges at its registered office in Form CHG-7, along with a copy of each instrument creating a charge. And section 85(2) says that register is open for inspection during business hours:

(a) by any member or creditor without any payment of fees; or (b) by any other person on payment of such fees as may be prescribed

If you are a creditor of the company, you have a statutory right to inspect its charge register, for free, at its registered office, subject only to reasonable restrictions the company’s articles may impose. Very few suppliers chasing a payment know this. Form CHG-7 has seventeen columns: one records the reasons for any delay in filing, another any condonation of it.

The clock on registering one

Section 77(1) puts the duty on the company:

It shall be the duty of every company creating a charge within or outside India, on its property or assets or any of its undertakings, whether tangible or otherwise, and situated in or outside India, to register the particulars of the charge signed by the company and the charge-holder together with the instruments, if any, creating such charge in such form, on payment of such fees and in such manner as may be prescribed, with the Registrar within thirty days of its creation

Thirty days by right. Then, for charges created on or after 2 November 2018, the provisos allow the Registrar to permit registration within sixty days on additional fees, and to allow a further sixty days after that on payment of ad valorem fees. That structure was put in by section 11 of the Companies (Amendment) Act 2019, given effect from 2 November 2018.

For a charge created today, these ordinary registration windows run to 120 days. Section 87 lets the Central Government rectify an omission or misstatement in a charge filing already made; since 2019 it no longer extends the time to register a new charge. Do not assume that a charge filed late was registered through the ordinary process. Charges created before that date had a longer, now closed, 300-day window.

If the company does not file, the lender can. Section 78 lets the charge holder apply to the Registrar, and the proviso entitles that person to recover the fees from the company. A competent lender does not rely on the borrower’s diligence.

What happens when nobody registers it

This is the part that gets misquoted constantly, because people cite one sub-section and stop. Read both:

(3) Notwithstanding anything contained in any other law for the time being in force, no charge created by a company shall be taken into account by the liquidator appointed under this Act or the Insolvency and Bankruptcy Code, 2016, as the case may be, or any other creditor unless it is duly registered under sub-section (1) and a certificate of registration of such charge is given by the Registrar under sub-section (2).

(4) Nothing in sub-section (3) shall prejudice any contract or obligation for the repayment of the money secured by a charge.

So an unregistered charge does not void the loan. The lender can still sue on the debt. What it loses is the ability to have the security counted by a liquidator or against a competing creditor. In a liquidation it effectively stands in the unsecured queue with everyone else.

Tribunals have applied that strictly. In an appeal decided by the National Company Law Appellate Tribunal on 19 October 2020, Company Appeal (AT) (Insolvency) No. 02 of 2020, the tribunal held that where a charge had not been registered under section 77(1), the creditor could not be treated as a secured creditor, notwithstanding that its security had been perfected under a different statute. An appeal against that decision was admitted by the Supreme Court in January 2021 and we have not found a final judgment in it, and later tribunal benches have read section 77(3) more narrowly in the context of a resolution process rather than a liquidation. The safe statement, and the one nobody disputes, is the core of it: an unregistered charge is not counted by a liquidator.

The asymmetry that actually costs people money

Here is the thing worth carrying away from this page.

Creating a charge is tightly policed. Releasing one is not.

The ordinary registration windows for a new charge run to 120 days. Satisfaction follows a different process. Section 82 gives the company thirty days from payment to tell the Registrar, and its proviso lets the Registrar allow the intimation within three hundred days on an application by the company or the charge holder. Beyond three hundred days it is still not lost: rule 12, as substituted in 2019, lets the Central Government direct an extension on an application in Form CHG-8 under section 87.

Repayment does not automatically record satisfaction. Under section 82, the company or charge holder can report it on Form CHG-4. Under section 83, the Registrar may record satisfaction or release on sufficient evidence even without the company’s intimation. Section 87 allows rectification of an omission or error. These processes update the recorded history; they do not erase the historical charge entry.

Rule 10(4) puts it beyond doubt for the company’s own register: “The register of charges shall be preserved permanently.”

A repaid loan can still show without a satisfaction date if nobody has recorded satisfaction with the Registrar. Ask for evidence before treating an old entry as a current debt.

How common is that? A regulator’s answer

We do not have a count of stale charges. A Reserve Bank of India circular of 13 September 2023 on the release of property documents on repayment, requires regulated lenders to:

release all the original movable / immovable property documents and remove charges registered with any registry within a period of 30 days after full repayment/ settlement of the loan account

That is one obligation covering both the papers and the register, not two. And where the delay is the lender’s, it must compensate the borrower ₹5,000 for each day of delay. The directions apply wherever the release fell due on or after 1 December 2023.

That directive concerns the personal loans covered by the RBI’s directions, not every company charge. It does not measure how many MCA entries remain without a satisfaction date after repayment.

The practical upshot for you: an open charge is a registered claim, not proof of a live debt. Treat it as a question to ask, not a conclusion to draw.

What the CHG-1 filing contains beyond the index

The index gives you the summary. The charge documents themselves, filed on Form CHG-1, contain a great deal more, and they are in the Charge Documents category of a company’s file.

CHG-1 captures the date of the instrument, the description of the property charged from a fixed taxonomy that runs from immovable property through movable property and book debts to uncalled share capital, the charge holder and its category, the amount secured, whether the charge is held by a consortium and whether the holders rank pari passu, and the principal terms including the rate of interest and the repayment term.

One field deserves special mention. The form asks whether the property being charged is not registered in the name of the company, and if so, in whose name it is. That is the kind of thing you would never think to ask and would very much want to know.

The same form is one of the few places in a company’s file where an individual property is described, down to the survey number and the boundaries. What that does and does not tell you about what a company owns is worth understanding before you treat a charge list as an asset list.

How to read open and satisfied charges

The tab gives a company eleven columns: a serial number, the SRN, the charge ID, the charge holder’s name, dates of creation, modification and satisfaction, the amount, an address, whether the charge was registered by another entity, and the asset holder’s name.

There is no status column. If Date of Satisfaction is empty, no satisfaction date is shown in the index. That is a question to investigate, not proof that the whole secured amount remains due.

What you see	How to read it
No charges at all	No charge shown in this index. Other security interests or unregistered claims may exist
Several charges, all satisfied	Satisfaction dates have been recorded. Check the filings if the history matters
Open charges, all several years old	The debt may still be due, or satisfaction may not have been recorded. Ask
A new charge in the last few months	A charge was recently registered; check its filing and creation date
Several new charges in quick succession	Read alongside the accounts and the filing history
A charge over “book debts” or receivables	Directly relevant if you are a trade creditor. The money owed to them is already pledged
A CHG-6 in the filings	Check whether it records appointment or cessation of a receiver or manager, and who filed it

Under section 84, a person who appoints a receiver or manager over charged property must notify the company and the Registrar. MCA’s CHG-6 instructions also cover notice of cessation. Read the form to see which event it records.

Does the charge amount show the outstanding loan?

No. The amount secured describes the charge, not the current loan balance. A ₹5 crore charge may secure less remaining principal, or the debt may already have been repaid without satisfaction being recorded.

Whether the asset is worth anything. No valuations here.

Whether an unregistered charge exists. By definition, an unregistered charge is not on the register. Section 77(3) reduces the incentive to leave one unregistered, and it does not eliminate the possibility.

And nothing about unsecured lending. Loans without security create no charge entry in this index, although they may appear in the company’s accounts.

Nor every security interest that exists. MCA’s own charge page carries a link out to CERSAI, the central registry of securitisation and asset-reconstruction security interests, and invites you to check the charges registered there for the same company. The registry is telling you, on its own page, that its index is not the whole picture.

And MCA does not vouch for it. The Master Data Services pages carry their own banner: “Master Data V3 Beta Version (Under Testing - Not to be used for statutory/ legal purposes)”. Read that against rule 7, which deems those same particulars to be the section 81 register, and you have the register’s operator telling you not to rely on the register for legal purposes. Both things are true at once. For a commercial decision the tab is the best free signal available; for anything that has to stand up formally, get the charge documents themselves.

What to do with it

1. Check the index of charges before you extend credit, pay a deposit, or buy an asset. It is a free starting point for identifying registered security interests.
2. Note which are open and how old they are. Old and open is a question, not an answer.
3. If a charge covers receivables or stock, and you are a supplier, understand that you are lending against assets a bank has already claimed. The full picture on a debtor reads charges alongside the accounts and the filing history.
4. Buying equipment or a vehicle from a company? Check charges first, and note that the ROC index is not the register that decides it: for a vehicle that is the registration certificate, and for plant it is the Central Registry. What to check before you buy a machine or a vehicle covers both, and the same logic applies before you pay any deposit.
5. If you are a creditor, remember section 85(2). You can inspect the company’s own register of charges, free, at its registered office.
6. Pull the CHG-1 itself if the amount matters. The index summarises; the form has the terms. It is one of the categories any ROC search report is expected to cover properly.

Contraventions of the charge provisions now carry a civil penalty under section 86, ₹5 lakh on the company and ₹50,000 on each officer in default, since the Companies (Amendment) Act 2020 took effect on 21 December 2020. That is the company’s problem. Yours is simpler: find out who is in front of you before you join the queue.

Written by the Entiva team, who read Indian company filings for a living. Not legal advice.