Registered Office under Sec 12 of the CA 2013: Avoid Rejection in INC-22 & INC-20A

Registered Office under Sec 12 of the CA 2013: Avoid Rejection in INC-22 & INC-20A. The registered office of a company or situation of registered office of the company as per section 12 required under the Companies Act, 2013 after every company gets incorporated at MCA. It is the legal correspondence address where all official ROC/RD/MCA communications, notices, and documents are served. After company registrations, companies are required to verify and situate their registered office with the Registrar of Companies (ROC) by filing Form INC-22 and commencement of business in Form INC-20A (in case of companies having share capital).
In recent months, the Ministry of Corporate Affairs (MCA) has been raising a specific objection that has become a frequent cause of resubmissions. The objection pertains to the non-submission or improper format of photographs of the registered office with GPS tagging and director/KMP presence.
The Latest MCA Objection You Must Watch Out For
Common MCA Objection
"It is observed that Photograph with GPS location of Registered Office showing external building and inside office also showing therein at least one director/ KMP who has affixed his/her Digital Signature to this form is not attached."
The above-cited objection is increasingly being raised during the scrutiny of both Form INC-22 (for verification or change of registered office) and Form INC-20A (for declaration of commencement of business), especially when companies upload incomplete or non-compliant photographs of the registered office. It is important to understand that this is not merely a documentation requirement but a significant compliance obligation under Section 12 of the Companies Act, 2013.
In fact, non-compliance with Section 12 is now one of the most commonly penalized offences by Registrar of Companies (ROC) and Regional Directors (RD), with frequent adjudication orders being issued under the Companies (Adjudication of Penalties) Rules. Some of the typical violations include:

Letterhead not conforming to the requirements of Section 12(3)

CIN (Corporate Identification Number) missing from letterhead

Omission of email ID or contact number on documents

Improper/ Typo or absent display of company name at the registered office

Letter head is not proper as per section 12

These may seem minor errors but are treated as statutory defaults and attract penalties under Section 12(8) of the Companies Act 2013. Hence, companies must check that full compliance not only while filing forms like INC-22 and INC-20A, but also in their day-to-day operations, signage, stationery, and communication.
Also learn how we can reduce the penalty under lesser penalty provisions for OPC, Startups and small companies under section 446B of the companies Act 2013.
What Does This Mean?
MCA expects companies to submit two recent photographs showing:

The external view of the registered office with proper nameplate.

The internal view with:

At least one Director or KMP (who signed the form),

A visible and functional office setup, and

GPS location metadata embedded or stamped.

What is a Registered Office?
Under Section 12 of the Companies Act, 2013, every company must:

Have a registered office within 30 days of incorporation (or at the time of incorporation via SPICe+).

Use it as the official address for communications from MCA and other regulators.

Display its name and statutory details at the entrance.

Documents Required for Form INC-22 (Registered Office Verification)
Photographs of the Registered Office
a) External Photograph

Should clearly show the building where the office is located.

Must have a name board displaying:

Company Name

Registered Office Address

CIN (Corporate Identification Number)

Email ID

Contact Number

GSTIN (if applicable)

b) Internal Photograph

Must show the inside of the office, including:

At least one Director/KMP who has signed the form.

Basic office infrastructure (desks, chairs, system, etc.).

Should include location and time stamp (GPS Metadata).

Note: Use apps like GPS Map Camera, Timestamp Camera, or MapCam to capture images with embedded GPS location and timestamp.
Proof of Office Address
Depending on whether the premises is owned or rented:

Owned: Title deed or ownership proof.

Rented/Leased:

Rent Agreement or Lease Deed.

Latest Rent Receipt.

No Objection Certificate (NOC) from the property owner.

Utility Bill (Not Older Than 2 Months)
Submit any one of the following:

Electricity Bill

Water Bill

Gas Bill

Telephone (landline) Bill

Note: Must check that the address on the bill matches the office address mentioned in the INC-22.
Documents Required for Form INC-20A (Commencement of Business)
Form INC-20A is required for companies with share capital, within 180 days of incorporation and the company may face the MCA adjudication notice in case of delay reporting of INC-20A even for 1 day. Hence please furnish all the required documents and details in the form INC-20A before filing especially the compliance of section 12 under the companies Act 2013 in regard to registered office and Pictures of the company with board and letter head compliances in CTC issuance. 
Bank Statement

Statement of the company’s current account showing subscription money to MOA has been received from the shareholders or 1st promoter

The amount should match the capital mentioned in the MOA (INC-33)

Transactions must show payment by the actual subscribers, cash deposits or journal entries are not acceptable.

Photographs of Registered Office

Same as required in INC-22: both external and internal views.

Must show the nameplate and director/KMP with GPS stamp.

How to Avoid MCA Objection in Registered Office Filings

Common Mistakes

What to Do Instead

Only external or only internal photo uploaded

Upload both views in a single PDF

Name board missing CIN/Email/GSTIN

Include all mandatory details on the board as per section 12 of the companies Act 2013

Director/KMP not visible in photo

Include the signing director/KMP visibly inside the office

Photos without GPS or time metadata

Use apps to embed GPS location and timestamp

Blurred or unclear photos

Use a high-resolution camera and label files properly

Utility bill older than 2 months

Always attach the latest bill, not older than two months

Penalties for Non-Compliance

Default

Penalty

Non-filing of INC-20A

Rs.50,000 for company + Rs.1,000/day (max Rs.1 lakh) per director

Invalid registered office

ROC may initiate strike-off proceedings

False declaration

Action under Section 447/448 (fraudulent filing)

Expert Support from Compliance Calendar LLP
At Compliance Calendar LLP, we help startups and companies for smooth ROC filings and to avoid MCA rejections/objections. Whether you're:

Registering your company as Private Limited, OPC company, Section 8 etc.

Shifting your registered office of the company

Filing Form INC-22 or INC-20A with MCA

ROC Filing annually

Company Compliances

Auditor appointment

Accounting, GST and TDS compliances

Posh Compliance

Share Certificate compliances

Minutes, registers and record maintenance

CFO Service

Dematerlisation of Shares

All other secretarial and legal services required from time to time to run the company.

The registered office of a company or situation of registered office of the company as per section 12 required under the Companies Act, 2013 after every company gets incorporated at MCA. It is the legal correspondence address where all official ROC/RD/MCA communications, notices, and documents are served. After company registrations, companies are required to verify and situate their registered office with the Registrar of Companies (ROC) by filing Form INC-22 and commencement of business in Form INC-20A (in case of companies having share capital).

In recent months, the Ministry of Corporate Affairs (MCA) has been raising a specific objection that has become a frequent cause of resubmissions. The objection pertains to the non-submission or improper format of photographs of the registered office with GPS tagging and director/KMP presence.

The Latest MCA Objection You Must Watch Out For

Common MCA Objection

"It is observed that Photograph with GPS location of Registered Office showing external building and inside office also showing therein at least one director/ KMP who has affixed his/her Digital Signature to this form is not attached."

The above-cited objection is increasingly being raised during the scrutiny of both Form INC-22 (for verification or change of registered office) and Form INC-20A (for declaration of commencement of business), especially when companies upload incomplete or non-compliant photographs of the registered office. It is important to understand that this is not merely a documentation requirement but a significant compliance obligation under Section 12 of the Companies Act, 2013.

In fact, non-compliance with Section 12 is now one of the most commonly penalized offences by Registrar of Companies (ROC) and Regional Directors (RD), with frequent adjudication orders being issued under the Companies (Adjudication of Penalties) Rules. Some of the typical violations include:

Letterhead not conforming to the requirements of Section 12(3)
CIN (Corporate Identification Number) missing from letterhead
Omission of email ID or contact number on documents
Improper/ Typo or absent display of company name at the registered office
Letter head is not proper as per section 12

Also learn how we can reduce the penalty under lesser penalty provisions for OPC, Startups and small companies under section 446B of the companies Act 2013.

What Does This Mean?

MCA expects companies to submit two recent photographs showing:

The external view of the registered office with proper nameplate.
The internal view with:

At least one Director or KMP (who signed the form),
A visible and functional office setup, and
GPS location metadata embedded or stamped.

What is a Registered Office?

Under Section 12 of the Companies Act, 2013, every company must:

Have a registered office within 30 days of incorporation (or at the time of incorporation via SPICe+).
Use it as the official address for communications from MCA and other regulators.
Display its name and statutory details at the entrance.

Documents Required for Form INC-22 (Registered Office Verification)

Photographs of the Registered Office

a) External Photograph

Should clearly show the building where the office is located.
Must have a name board displaying:

Company Name
Registered Office Address
CIN (Corporate Identification Number)
Email ID
Contact Number
GSTIN (if applicable)

b) Internal Photograph

Must show the inside of the office, including:

At least one Director/KMP who has signed the form.
Basic office infrastructure (desks, chairs, system, etc.).

Should include location and time stamp (GPS Metadata).

Note: Use apps like GPS Map Camera, Timestamp Camera, or MapCam to capture images with embedded GPS location and timestamp.

Proof of Office Address

Depending on whether the premises is owned or rented:

Owned: Title deed or ownership proof.
Rented/Leased:

Rent Agreement or Lease Deed.
Latest Rent Receipt.
No Objection Certificate (NOC) from the property owner.

Utility Bill (Not Older Than 2 Months)

Submit any one of the following:

Electricity Bill
Water Bill
Gas Bill
Telephone (landline) Bill

Note: Must check that the address on the bill matches the office address mentioned in the INC-22.

Documents Required for Form INC-20A (Commencement of Business)

Form INC-20A is required for companies with share capital, within 180 days of incorporation and the company may face the MCA adjudication notice in case of delay reporting of INC-20A even for 1 day. Hence please furnish all the required documents and details in the form INC-20A before filing especially the compliance of section 12 under the companies Act 2013 in regard to registered office and Pictures of the company with board and letter head compliances in CTC issuance.

Bank Statement

Statement of the company’s current account showing subscription money to MOA has been received from the shareholders or 1st promoter
The amount should match the capital mentioned in the MOA (INC-33)
Transactions must show payment by the actual subscribers, cash deposits or journal entries are not acceptable.

Photographs of Registered Office

Same as required in INC-22: both external and internal views.
Must show the nameplate and director/KMP with GPS stamp.

How to Avoid MCA Objection in Registered Office Filings

Common Mistakes	What to Do Instead
Only external or only internal photo uploaded	Upload both views in a single PDF
Name board missing CIN/Email/GSTIN	Include all mandatory details on the board as per section 12 of the companies Act 2013
Director/KMP not visible in photo	Include the signing director/KMP visibly inside the office
Photos without GPS or time metadata	Use apps to embed GPS location and timestamp
Blurred or unclear photos	Use a high-resolution camera and label files properly
Utility bill older than 2 months	Always attach the latest bill, not older than two months

Penalties for Non-Compliance

Default	Penalty
Non-filing of INC-20A	Rs.50,000 for company + Rs.1,000/day (max Rs.1 lakh) per director
Invalid registered office	ROC may initiate strike-off proceedings
False declaration	Action under Section 447/448 (fraudulent filing)

Expert Support from Compliance Calendar LLP

At Compliance Calendar LLP, we help startups and companies for smooth ROC filings and to avoid MCA rejections/objections. Whether you're:

Registering your company as Private Limited, OPC company, Section 8 etc.
Shifting your registered office of the company
Filing Form INC-22 or INC-20A with MCA
ROC Filing annually
Company Compliances
Auditor appointment
Accounting, GST and TDS compliances
Posh Compliance
Share Certificate compliances
Minutes, registers and record maintenance
CFO Service
Dematerlisation of Shares
All other secretarial and legal services required from time to time to run the company.