How to Check a Company's RTA and Folio Details

Checking RTA and folio details is two separate jobs that people run together: finding out which registrar handles a particular company's shareholder records, and finding out whether your own physical folio is compliant enough to be serviced. This page covers both, from the regulations that actually place the details in public and the current master circular that sets what a folio must carry.

Where a company's RTA is disclosed

Three routes, in order of reliability.

1. The annual report. Schedule V(C)(9) of the LODR Regulations sets out the General Shareholder Information block of the corporate governance report, and item (i) is the registrar to an issue and share transfer agents. Item (j) is the share transfer system and item (p) is the address for correspondence, so the whole servicing chain sits in one place, dated to that financial year. Reading the rest of that report is covered in how to read a corporate governance report.

2. The company's and the exchange's websites. RTAs must provide their complete contact details, postal address, phone numbers and email address, on their own websites, and the same must appear on the websites of the listed companies they serve and of the exchanges those companies are listed on. The RTA must update this forthwith whenever it changes.

3. The tripartite agreement trail. Where a company changes registrar, LODR regulation 7(4) requires a tripartite agreement between the outgoing registrar, the incoming registrar and the listed entity, and regulation 7(5) requires the appointment to be intimated. A change of RTA is therefore a disclosed event, not a silent one.

One thing that no longer exists is worth knowing about: the regulation 7(3) compliance certificate, signed jointly by the compliance officer and the share transfer agent and filed within thirty days of the financial year end, was omitted with effect from 13 December 2024. Do not go looking for a filing that was deleted.

What a physical folio has to carry

Since SEBI's common and simplified norms, four things are mandatory for every holder of physical securities in a listed company, against each folio number.

What happens to a folio that is not updated

The consequences are specific, and narrower than the version most secondary write-ups still carry.

A holder whose folio does not have PAN, contact details, bank account details and specimen signature updated is eligible:

• to lodge a grievance or get any service request from the RTA only after furnishing PAN and KYC details; and
• for any payment including dividend, interest or redemption on that folio only through electronic mode, with effect from 1 April 2024, with the listed company intimating the holder that a payment is due and will be made electronically once the requirements are met.

There is one carve out that matters. The provisions on furnishing PAN and KYC details do not apply to requests from investors for dematerialisation of physical securities. A holder who wants to move the certificate into a demat account is not blocked by an incomplete folio, which is the practical route out of the problem. The mechanics of that conversion are in what is dematerialisation of shares.

How to actually get a folio updated

• Use the ISR forms. SEBI prescribes standard forms for registering and updating KYC and for the various service requests, listed at the annexures to the master circular. Form ISR-1 is the registration and update form.
• Update every folio at once. On specific authorisation in Form ISR-1, the RTA updates PAN and KYC across all folios of that holder that it manages, overwriting what it already has.
• Reuse your demat KYC. Submit a Client Master List, signed and stamped by your depository participant, along with Form ISR-1, and the RTA will update present address, bank details, email address and mobile number from it, including details not previously on the physical folio.
• Self-attestation is enough. Self-attested copies are accepted for processing service requests unless the Companies Act, its rules, or a SEBI regulation or circular says otherwise.
• No indemnity for routine requests. Indemnity is not required for any service request except transmission and issuance of duplicate certificates, unless specifically prescribed.
• All objections come at once. RTAs must raise all objections in one instance while processing a service request, and may seek further information only where there is a deficiency or discrepancy in what was furnished.

Documents can go to the RTA by in person verification, by post, or electronically with e-sign.

If the registrar does not respond

The escalation path is the same as for any SEBI registered intermediary. RTAs are covered by the SCORES complaint system with the stock exchanges as the designated body above them, and a dispute that survives SCORES goes to the Online Dispute Resolution portal. A company's own complaint record, including how many shareholder grievances arrived and how many were resolved, is a disclosure in its own right and is covered in how to check a company's investor complaint record.

So checking RTA and folio details comes down to reading Schedule V(C)(9) of the annual report for the registrar, and checking four fields against your folio before you need anything from it.

Flock reports the filings themselves, each one dated and linked to its source. What any disclosure means for your money is your call to make. Not investment advice.