A charge filing is not complete merely because a form was uploaded. The company should be able to show what event occurred, which document created or changed the security, when the deadline started, what the ROC accepted and how the internal charge register was updated.
This guide follows that work from creation to closure. It focuses on CHG-1 for a non-debenture charge and CHG-4 after full satisfaction. If you first need to decide between CHG-1 and CHG-9, or understand delayed-registration limits, use CA Samaaj's CHG-1 vs CHG-9 decision guide.
The legal base is Chapter VI of the Companies Act, 2013. Rule 3 of the Companies (Registration of Charges) Rules, 2014 prescribes CHG-1 for creation or modification of a charge other than one related to debentures. Section 82 and Rule 8 deal with satisfaction through CHG-4.
Start by identifying the exact event
Do not begin with the form name. First identify what legally happened. That decision controls the document pack, trigger date and expected ROC certificate.
| Event | Usual filing route | Completion evidence |
|---|---|---|
| New non-debenture charge | CHG-1 | ROC registration certificate in CHG-2 |
| Modification of a registered non-debenture charge | CHG-1, referring to the existing charge | ROC modification certificate in CHG-3 |
| Full payment or satisfaction of a registered charge | CHG-4 | Satisfaction recorded by ROC and certificate in CHG-5 |
| Charge related to debentures | Evaluate CHG-9, not CHG-1 | Certificate appropriate to creation or modification |
A repayment is not automatically a satisfaction filing. CHG-4 applies when the registered charge has been paid or satisfied in full. If only part of a facility is repaid, check whether the security continues unchanged or whether the registered terms, amount or extent have been modified.
Build the CHG-1 file before opening the form
For creation or modification, prepare one working folder containing the documents and a short reconciliation. At minimum, read the executed security instrument and confirm:
- the legal name and identity of the company and charge-holder;
- the date on which the charge was created or modified;
- the amount secured and any maximum amount stated in the instrument;
- the assets, property or undertaking covered by the security;
- whether the charge relates to debentures; and
- for a modification, the existing charge details and exactly what changed.
Rule 3 requires the prescribed particulars and a copy of the instrument creating or modifying the charge. It also requires the filing to be signed by the company and the charge-holder. The rule separately explains who may verify the copy of the instrument, depending on whether the secured property is in India or outside India.
Use the executed document as the source. A sanction letter, board note or loan disbursement entry may help the file, but it should not replace the instrument that actually creates or modifies the security.
Fix the trigger date and control the deadline
Section 77 sets the normal registration period at 30 days from creation of the charge. Section 79 applies the same framework, so far as may be, to a modification and to property acquired subject to a charge. The compliance tracker should therefore show the document date, the legal event date and the filing due date separately.
Do not count mechanically from the loan sanction, first drawdown or accounting entry. Read the documents to determine when the charge was legally created or modified. Treat 30 days as the operating deadline. Do not plan around an additional-fee window.
If the company has missed 30 days, stop and check the current statutory route and fees before filing. Section 77 now contains different treatment for older charges and charges created under the newer framework. The related CHG-1 vs CHG-9 guide explains that timing split without duplicating it here.
Check the CHG-1 submission against one reconciliation sheet
Before submission, compare the proposed form particulars with the instrument and the company's records. A simple control sheet can prevent common resubmissions.
| Control | Compare with | Question to close |
|---|---|---|
| Event date | Executed security or amendment document | What clause and document created or modified the charge? |
| Secured amount | Instrument, facility documents and existing ROC charge | Do the amount and currency agree? |
| Property description | Instrument and asset/security schedule | Can the secured assets be identified consistently? |
| Charge-holder | Instrument and company master records | Is the legal name correct and current? |
| Existing charge reference | ROC record and earlier certificate | For a modification, is the correct registered charge being updated? |
| Signatures and verification | Rule 3 and current form workflow | Have both sides completed the required authentication? |
Portal labels, attachment limits and fee displays can change. For a live filing, use the current MCA form and on-screen validation. Do not rely on a saved screenshot or an old instruction kit as the only source.
Submission is not the end of CHG-1
Keep the service request number, payment evidence and submitted form, but continue tracking the case until the ROC outcome is available. A payment receipt only proves that a payment or submission step occurred.
Under Rule 6, the Registrar issues:
- CHG-2 when creation of a charge is registered; and
- CHG-3 when modification of a charge is registered.
Rule 6 states that these certificates are conclusive evidence that the Chapter VI registration requirements for creation or modification have been complied with. If the case is marked for resubmission, close the query and verify the final certificate instead of treating the first upload as completion.
How to handle a modification
A modification changes the terms, conditions, extent or operation of an existing registered charge. Examples may include an increase in the secured limit, addition or release of secured assets, a change in ranking or another documented change affecting the registered security. The exact filing conclusion depends on the executed amendment and the existing ROC record.
Prepare a short before-and-after note:
- Quote the existing registered particulars.
- Identify the amendment document and its effective date.
- List only the terms that changed.
- Reconcile the amended particulars to the existing charge ID.
- After filing, retain CHG-3 and update the internal records.
This makes later audit and lender confirmation easier. It also avoids creating a disconnected record when the correct action is to modify an existing charge.
CHG-4 after full satisfaction
Section 82 requires the company to intimate full payment or satisfaction within 30 days. It permits the Registrar, on application by the company or charge-holder, to allow the intimation within 300 days on payment of prescribed additional fees. Rule 8 prescribes CHG-4 for this intimation.
Before filing CHG-4, collect the lender's confirmation of full satisfaction, identify the payment or satisfaction date and reconcile the charge ID. If the charge-holder signs the prescribed intimation, Section 82 says the Registrar need not send the separate notice. Otherwise, the Registrar may ask the charge-holder to show cause, within a period not exceeding 14 days, why satisfaction should not be recorded.
The process closes only after the ROC records satisfaction. Rule 8 provides for a certificate in CHG-5. Save that certificate and confirm that the public charge record reflects the correct status.
Update CHG-7 and the supporting records
Rule 10 requires the company to keep its register of charges in CHG-7 at the registered office. The register covers creation, property acquired subject to a charge, modification and satisfaction. Entries are made forthwith and authenticated by a director, company secretary or another person authorised by the Board.
The CHG-7 register is preserved permanently. Instruments creating or modifying a charge are preserved for eight years from the date of satisfaction. The loan register, security schedule and lender confirmation file should agree with the ROC record and CHG-7.
Worked lifecycle example
Assume a company signs a deed creating a non-debenture charge over plant and receivables. Its internal target is to file CHG-1 well before day 30. The team reconciles the deed, secured amount and asset schedule, completes the required authentication, submits the form and tracks the matter until CHG-2 is issued.
Six months later, an executed amendment increases the secured limit and adds a warehouse to the security package. The team compares the amendment with the existing ROC charge, files the modification through CHG-1 and retains CHG-3.
After the facility is fully repaid, the lender confirms full satisfaction. The team files CHG-4 using the correct charge ID, tracks the ROC record until CHG-5 is issued, updates CHG-7 and retains the charge instruments for the required period.
Final handover checklist
- Executed creation or modification instrument is in the file.
- Trigger date and normal 30-day deadline are documented.
- Form particulars reconcile with the instrument and ROC record.
- Required company and charge-holder authentication is complete.
- Submitted form, payment trail and service request number are saved.
- CHG-2, CHG-3 or CHG-5 is obtained for the relevant event.
- Any resubmission query is closed and final status is checked.
- CHG-7, loan register and security schedule are updated.
- For delayed or disputed cases, the current legal route is reviewed before action.
The best control is one lifecycle file for each charge. It should connect the legal document, ROC submission, certificate and internal register from creation to final satisfaction.
