Full satisfaction starts a separate workflow
Companies Act section 82 requires intimation of payment or satisfaction in full of a registered charge within thirty days of that event. This is distinct from creating or modifying security under section 77. Confirm that the relevant secured obligation and charge are actually satisfied in full: a principal repayment, temporary nil utilisation or sanction cancellation does not by itself resolve every interest, guarantee or continuing-security term. This ordinary-company guide was checked on 29 October 2026. ICSI statutory text: Companies Act section 82. ICSI statutory text: Companies Act section 82.
Read the Act and rule together
Section 82’s proviso permits the Registrar, on application by the company or charge holder, to allow intimation within 300 days with prescribed additional fees. Rule 8 identifies CHG-4 and its 300-day wording. Do not use that rule to erase the Act’s initial thirty-day duty or describe every day up to 300 as automatically timely. Fees and portal requirements depend on the applicable facts; no flat fee or unverified holiday extension is assumed. ICSI statutory text: Companies Act section 82.
Separate lender evidence from Registrar completion
Retain the release/no-dues evidence and the charge-holder’s authority to sign. Under section 82(2), the Registrar ordinarily calls on the holder to show cause within the specified period, not exceeding fourteen days. That notice is unnecessary where the specified intimation is signed by the charge holder. If cause is shown, subsection (3) requires the note and company intimation. A unilateral internal ledger closure therefore cannot substitute for the relevant statutory evidence and Registrar action. ICSI statutory text: Companies Act section 82.
Close with the correct certificate
Rule 8(2) provides CHG-5 when the Registrar records full satisfaction under section 82 or 83. Keep the original charge ID, CHG-4 acknowledgement, holder evidence and issued CHG-5 together. Distinguish a submission awaiting processing from an entry actually made. Section 82(4) preserves the Registrar’s section 83 and other entry powers; do not assume this workflow exhausts every route or dispute concerning the register. ICSI statutory text: Companies Act section 82.
Escalate a missed outer period accurately
Rule 12 addresses a Central Government application in CHG-8, including extension for satisfaction filings not made within 300 days. It also addresses specified omissions or misstatements in previously recorded particulars. It is a distinct relief route; do not promise automatic condonation or transfer its satisfaction-filing logic to an omitted new charge-creation case. The scope and conditions of any resulting order must be checked on the actual file. Charges Rules, rule 12. ICSI statutory text: Companies Act section 82.
Maintain one closure register across facilities
Track each charge separately even where one lender provides a consolidated no-dues letter. Identify the legally established full-satisfaction date, not merely the letter’s issue date. Record filings, deficiencies and the certificate for each charge; a part release may instead need modification analysis. The numerical examples use ordinary elapsed calendar-day counting after stipulated event dates, without special relief or closure adjustments. They are planning workings, not a promise that a later filing will be allowed. Charges Rules, rule 8. ICSI statutory text: Companies Act section 82.
Applicable primary references
ICSI statutory text: Companies Act section 82 ICSI: Charges Rules, rule 8 ICSI: Charges Rules, rule 12
Six worked illustrations
All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.
Illustrative example 1: Thirty-day calendar
A registered charge is fully satisfied on 1 October 2026. Thirty elapsed calendar days gives 31 October. An internal target of 26 October leaves five calendar days before that computed endpoint; the internal target is only a planning control.
Illustrative example 2: Conditional outer period
For the same stipulated 1 October satisfaction, 300 elapsed days ends on 28 July 2027. The extra span beyond day thirty is 270 days, not another 300 days after the thirty-day period. Application and fee conditions still apply.
Illustrative example 3: Principal-only closure is incomplete on the facts
A facility shows principal ₹50 lakh paid, but the stipulated secured interest remains ₹1 lakh and secured charges ₹25,000. The remaining identified obligation is ₹1.25 lakh. Do not infer full satisfaction solely from a nil principal ledger; examine the instrument and lender confirmation.
Illustrative example 4: Two charges with different dates
Charge A is fully satisfied on 1 October 2026, Charge B on 20 October. Their thirty-day endpoints are 31 October and 19 November, nineteen days apart. A combined lender letter dated 25 October does not automatically replace either underlying date.
Illustrative example 5: Notice period actually specified
Assume a valid Registrar notice received on 2 November specifies ten elapsed days for the response, with the assumed count beginning the next day. The model endpoint is 12 November. Ten is four fewer than the statutory maximum fourteen; the holder cannot simply replace the specified period with fourteen.
Illustrative example 6: A day beyond the 300-day model
Satisfaction is stipulated on 1 October 2026, but review occurs on 29 July 2027, 301 elapsed days later. That is one day beyond the modelled 300-day stage. Review rule 12’s CHG-8 relief route rather than representing the filing as within the ordinary 300-day period.
Ten-step verification table
| Step | Action | Evidence |
|---|---|---|
| 1 | Identify the registered charge | Match charge ID, holder and instrument. |
| 2 | Review all secured obligations | Check principal, interest, guarantees and continuing terms. |
| 3 | Establish full satisfaction | Retain the actual event evidence and lender confirmation. |
| 4 | Calculate the initial deadline | Build the thirty-day calendar from the supported date. |
| 5 | Assess any delayed stage | Check application, additional fees and 300-day scope. |
| 6 | Prepare CHG-4 evidence | Verify signatories, holder authority and supporting particulars. |
| 7 | Monitor any show-cause notice | Use the actual specified period and retain responses. |
| 8 | Escalate beyond 300 days | Review rule 12 relief without assuming approval. |
| 9 | Obtain CHG-5 | Preserve the Registrar’s completed satisfaction certificate. |
| 10 | Reconcile the closure register | Keep every facility’s debt, security and ROC status distinct. |
Sixteen practitioner FAQs
1. Does nil principal always mean full satisfaction?
No. Review the actual secured obligations and instrument.
2. What is the initial Act deadline?
Thirty days from payment or satisfaction in full.
3. Does rule 8 erase that duty?
No. Read it with section 82 and its conditional relief proviso.
4. Who may seek the stated 300-day allowance?
The company or charge holder under the proviso.
5. Is that 300 days after day thirty?
No. It runs from the satisfaction event.
6. What form identifies the satisfaction intimation?
CHG-4 under rule 8.
7. Does an internal journal complete the ROC process?
No. Filing and Registrar action need separate evidence.
8. Is holder signature relevant to notice?
Yes. Section 82(2) contains the specified signed-intimation exception.
9. What is the stated maximum show-cause period?
Fourteen days, with the actual notice specifying the period.
10. Can the holder always take the maximum despite a shorter notice?
Do not disregard the valid period actually specified.
11. What if the holder shows cause?
Review subsection (3)’s note and company-intimation process.
12. Which certificate evidences recorded full satisfaction?
CHG-5 under rule 8(2).
13. Is filing acknowledgement identical to that certificate?
No. Preserve both stages separately.
14. What route needs review after 300 days?
Rule 12’s CHG-8 extension route, on its actual conditions.
15. Does CHG-8 guarantee automatic approval?
No.
16. Can the company close all charges using one unanalysed letter date?
No. Establish and track each charge’s actual satisfaction event.
Conclusion
Full payment or satisfaction of a registered charge triggers a separate filing duty. Reconcile the actual satisfaction date, statutory thirty days, conditional 300-day relief and the final CHG-5 certificate rather than treating a bank closure letter as the completed ROC process.