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DIN Intimations under Sections 156–158: Separate the Director’s Month, Company’s Fifteen Days and Pe

DIN Intimations under Sections 156–158: Separate the Director’s Month, Company’s Fifteen Days and Penalty Model

DIN allotment, director-to-company intimation and company-to-Registrar reporting are separate events. Track each company’s actual receipt date and use the current section 157 penalty wording rather than historical fine provisions.

Reviewed by CA BB Gupta · Chartered Accountant & Company Secretary | 45+ years in corporate matters

Director signs important corporate documents

Do not use DIN allotment, the director’s intimation and the company’s reporting as one interchangeable event. Section 156 gives the existing director one month from receipt of DIN to intimate every company where the person is a director. Section 157 gives each company fifteen days from receipt of that intimation to furnish the DIN information in the prescribed manner.

Use current statutory text

The official section 156 text and current official section 157 text were checked on 25 October 2026. The Companies Act, sections 155–158 also supply the single-DIN and DIN-mention framework. Historical compilations may carry superseded penalty wording; the current section 157(2) penalty text is used below. This article concerns statutory event tracking and evidence, not an assertion that every current appointment is processed through a new standalone DIN intimation.

Retain separate evidence at every hand-off

Record DIN receipt by the director, the director’s communication to each relevant company, company receipt and actual Registrar submission/acceptance. A message to one group company is not proof that all companies received it. An internal prepared form is not an accepted filing. Verify the prescribed form, manner, applicable fees and current filing route for the actual event; appointment returns, changes to particulars and periodic KYC are separate compliance populations and should not be treated as automatic substitutes.

A month is not always thirty days

The director’s statutory period is one month; the company’s period is fifteen days from its own receipt. Build distinct date fields rather than one shared reminder. The illustrations use simple dates with no month-end ambiguity and exclude the receipt day for elapsed-day models. They assume no special extension or holiday rule changes the accepted deadline; verify those matters in an actual file. The company should not wait until the director’s outer month ends if the company received the intimation earlier.

Apply penalties as legal conclusions, not invoice charges

Current section 157(2) provides the company ₹25,000 and, for continuing failure, ₹100 for each day after the first, capped at ₹1 lakh. It separately addresses each officer in default, with the stated base and continuing component. The models below isolate the company calculation on independently established default days; they do not decide officer liability, adjudication, statutory concessions for a particular company or the amount an authority will finally impose. Section 158 separately requires DIN mention in returns/information/particulars relating to or referring to directors. A penalty payment does not cure inaccurate DIN data or complete an omitted filing.

Six worked illustrations

All facts and amounts below are fictional. Assumptions describe the model, not additional statutory rules.

Illustrative example 1: Company receipt date

Assume section 156 intimation reaches the company on 1 September 2026. Fifteen elapsed days gives the model section 157 date of 16 September. The director’s earlier DIN receipt is not substituted for the company’s own receipt.

Illustrative example 2: Earlier intimation creates an earlier company clock

Director receives DIN on 10 August 2026: the simple one-month model ends 10 September. Company receives intimation on 20 August: fifteen elapsed days gives 4 September. Waiting until 10 September would already be six days beyond that company deadline.

Illustrative example 3: Three companies have separate receipts

Assume companies A, B and C receive intimation on 1, 3 and 7 September 2026. Their model fifteen-day dates are 16, 18 and 22 September respectively. Three company obligations do not create three DINs for the same person.

Illustrative example 4: First established default day

Assume an ordinary company’s section 157(2) failure is legally established for one day and the stated model applies without other relief. Company penalty model is ₹25,000 + ₹100 × 0 = ₹25,000. No continuing-day addition is applied to the first day.

Illustrative example 5: Ten established default days

On the same isolated company assumptions, ten total failure days mean nine days after the first. ₹25,000 + ₹100 × 9 = ₹25,900. Do not count ten continuing additions or assume this also settles each officer’s separate position.

Illustrative example 6: Model the cap without claiming elapsed current default

A hypothetical 751-day failure gives ₹25,000 + ₹100 × 750 = ₹1,00,000. A hypothetical 900-day raw amount ₹1,14,900 is limited to ₹1,00,000 in this company-only model. These are duration illustrations, not a claim that such a default began or elapsed during 2026.

Ten-step verification table

StepActionEvidence
1Identify the relevant eventDIN allotment/intimation versus appointment, change or KYC.
2Verify the existing DINAuthoritative DIN and identity evidence; no duplicate application.
3Record director receiptReceipt evidence for section 156’s month.
4Map every relevant companyDirectorship list and individual communication records.
5Capture company receiptsSeparate date and acknowledgement for each company.
6Calculate distinct deadlinesMonth calculation and company-specific fifteen-day working.
7Confirm prescribed filing routeCurrent form, manner, fees and applicable rules.
8Check DIN mentionReturns and particulars referring to directors under section 158.
9Reconcile completion and defaultsAccepted submission evidence and actual outstanding period.
10Assess consequences separatelyCurrent law, company status, authority order and officer-specific analysis.

Sixteen practitioner FAQs

1. Does DIN allotment itself prove company intimation?

No. Preserve the separate communication and receipt evidence.

2. What period does section 156 specify?

One month from the existing director’s receipt of DIN.

3. Is one month invariably thirty days?

No. Calculate the calendar-month period correctly.

4. What starts the company’s fifteen days?

Its receipt of the section 156 intimation.

5. Can the company wait until the director’s month ends?

Not if its own fifteen-day period has already started and expires earlier.

6. Must every relevant company be considered?

Section 156 refers to the company or all companies where the person is a director.

7. Does one person need a DIN for each company?

No. Section 155 prohibits applying for, obtaining or possessing another DIN after allotment.

8. Is a draft form proof of completed submission?

No. Retain actual submission and acceptance evidence.

9. Are appointment returns and KYC identical to this event?

No. Classify the obligation and verify the applicable prescribed route.

10. What does section 158 require?

DIN mention in the specified returns, information or particulars relating to or referring to directors.

11. What company base is used in the ordinary penalty model?

₹25,000 under current section 157(2), subject to applicable legal assessment.

12. Does the first day receive the continuing ₹100 addition?

The wording counts continuing days after the first.

13. What company cap is illustrated?

₹1 lakh under the cited ordinary company model.

14. Are officer penalties automatically included in that company amount?

No. The statutory officer-in-default position is separate.

15. Does the model determine statutory concessions or adjudication?

No. Apply the actual company population, law and authority’s order.

16. Does paying a penalty complete the filing?

No. Verify correct information and actual completion separately.

Conclusion

DIN allotment, director-to-company intimation and company-to-Registrar reporting are separate events. Track each company’s actual receipt date and use the current section 157 penalty wording rather than historical fine provisions.

Sources and primary references