E-CHNG and E-CON Forms: MCA Replaces 9 Incorporation Forms in 2026
The E-CHNG and E-CON forms are two new consolidated MCA forms that replace 9 existing incorporation and change-related filings under the Companies (Incorporation) Amendment Rules, 2026. MCA issued a public notice on April 8, 2026, under Policy Reference CL-V Section, Policy-01/2/2025-CL-V-MCA-Part(2), proposing E-CHNG (Parts A through F) for company changes and E-CON (Parts A through E) for company conversions. The comment period closes on May 9, 2026, and the rules take effect upon publication in the Official Gazette. A third form, INC-11D, is introduced as a new certificate for Part XXI conversions.
- E-CHNG (Parts A-F) consolidates 6 change-related forms: INC-22, INC-23, INC-24, INC-28, and RD-1.
- E-CON (Parts A-E) consolidates 4 conversion-related forms: INC-6, INC-18, INC-20, and INC-27.
- INC-11D is a brand-new certificate form for Part XXI conversions (not a replacement).
- Notified via public notice dated April 8, 2026; comment deadline is May 9, 2026.
- Effective date: upon publication in the Official Gazette.
- Old forms (INC-22, INC-24, RD-1, etc.) will be deactivated on MCA V3 after the transition.
- Filing fees, compliance deadlines, and digital signature requirements remain unchanged.
- LLPs and partnership firms are not affected; these forms apply only to companies under the Companies Act, 2013.
Why MCA Is Consolidating 9 Forms into E-CHNG and E-CON
Think of the old MCA form system as a toolbox where every task had its own single-purpose screwdriver. Need to change your company name? File INC-24. Shifting your registered office within the same state? File INC-22. Moving to a different state? That is INC-23. Applying to the Regional Director? Use RD-1. Filing the Regional Director's order? Now you need INC-28. Each form had its own format, its own fee structure reference, and its own set of attachments.
This fragmentation created real problems. Between January 2024 and March 2026, MCA processed over 4.2 lakh filings across these 9 forms. Companies frequently filed the wrong form for the right purpose, CS professionals spent billable hours decoding which form applied to which change, and the MCA V3 portal had to maintain 9 separate form templates with overlapping data fields.
The consolidation into E-CHNG and E-CON addresses three specific inefficiencies:
- Reduced form duplication: INC-22 and INC-23 both dealt with registered office changes but for different jurisdictions. E-CHNG Parts B, C, and D now house all registered office filings under one form umbrella.
- Unified conversion pathway: Converting an OPC (INC-6), a public company (INC-18), or a Part XXI entity (INC-27) previously required 3 different forms. E-CON brings all conversion filings into Parts A through E.
- Portal simplification: The MCA V3 portal can now render one form with conditional parts instead of loading 9 distinct form schemas. This aligns with the MCA V3 portal's modular design philosophy.
This is the same approach MCA took when it introduced SPICe+ to consolidate company incorporation filings. The E-CHNG and E-CON forms extend that logic to post-incorporation changes and conversions.
Complete Old-to-New Form Mapping: E-CHNG and E-CON
The table below is the definitive mapping of every old MCA form to its replacement under the Companies (Incorporation) Amendment Rules, 2026. Bookmark this for reference when the V3 portal transitions.
| Old Form | Old Form Purpose | New Form | New Part | Category |
|---|---|---|---|---|
| INC-24 | Application for Central Government approval of company name change | E-CHNG | Part A | Change |
| INC-22 | Notice of situation or change of registered office (within same state, same ROC) | E-CHNG | Part B | Change |
| INC-22 | Verification of registered office address | E-CHNG | Part C | Change |
| INC-23 | Application to Regional Director for shifting registered office to another state | E-CHNG | Part D | Change |
| RD-1 | Application to Regional Director | E-CHNG | Part E | Change |
| INC-28 | Order of Regional Director or Central Government | E-CHNG | Part F | Change |
| INC-18 | Application for conversion of public company into private company | E-CON | Part A | Conversion |
| INC-20 | Intimation to Registrar of approval of conversion | E-CON | Part B | Conversion |
| INC-6 | One Person Company conversion application | E-CON | Part C | Conversion |
| INC-27 | Conversion of companies already registered under previous Acts | E-CON | Part D | Conversion |
| INC-18 / INC-20 | Section 8 company conversion application and intimation | E-CON | Part E | Conversion |
INC-22 currently serves two purposes: (1) change of registered office address, and (2) verification of registered office. Under E-CHNG, these split into Part B (address change) and Part C (verification). If you are filing both a change and verification simultaneously, you need to complete both Part B and Part C of E-CHNG.
For a broader view of all 2026 MCA rule changes, see our coverage of the Companies (Incorporation) Amendment Rules, 2026 key changes.
E-CHNG Form: Detailed Breakdown of Parts A Through F
E-CHNG stands for "Electronic Change" and covers every post-incorporation modification that a company files with MCA, except conversions. Here is what each part does, which old form it replaces, and the legal section that governs it.
Part A: Company Name Change (Replaces INC-24)
E-CHNG Part A is the new form for applying for Central Government approval to change a company's name. Under Section 13(2) of the Companies Act, 2013, a company can change its name by passing a special resolution and obtaining Central Government approval through the Registrar of Companies.
The key requirements remain identical to INC-24:
- Special resolution passed by shareholders (75% majority).
- Name availability confirmed via RUN (Reserve Unique Name) service or SPICe+ Part A. For the latest name reservation rules, refer to our guide on new company name reservation rules 2026.
- No name change allowed within 3 years of the last name change without Central Government approval.
- DSC (Digital Signature Certificate) of the director and the practicing professional certifying the form.
What changes: the form structure, SRN format, and the V3 portal interface. What stays the same: the legal requirements, timelines, and the ₹1,000 to ₹5,000 fee slab based on authorized capital.
Part B: Registered Office Change Within Same State and ROC (Replaces INC-22)
E-CHNG Part B handles the most common type of registered office change: moving your office within the same city or district, staying under the same ROC jurisdiction. This replaces the change component of INC-22.
Filing deadline: within 30 days of the board resolution approving the change, consistent with Section 12(4) of the Companies Act, 2013.
Required attachments include proof of the new address (utility bill not older than 2 months), NOC from the property owner, and the board resolution. If you need step-by-step guidance on address changes, see our detailed page on change of registered office address.
Part C: Verification of Registered Office (Replaces INC-22 Verification)
E-CHNG Part C is the verification component that was previously bundled inside INC-22. Every newly incorporated company must verify its registered office within 30 days of incorporation. This verification confirms that the company actually occupies the declared address.
Post-transition, the MCA V3 portal will present Part C as a standalone filing within the E-CHNG form. This separation makes it clearer for newly incorporated companies that verification is a distinct compliance step, not just a subsection of the address change form.
Part D: Interstate Registered Office Shift (Replaces INC-23)
E-CHNG Part D covers the more complex scenario: shifting a company's registered office from one state to another. This replaces INC-23 and requires Regional Director approval under Section 13(4) of the Companies Act, 2013.
The process involves:
- Passing a special resolution for the alteration of the Memorandum of Association (MOA).
- Filing E-CHNG Part D (replacing INC-23) with the Regional Director.
- Publishing a notice in a newspaper with circulation in both the old and new states.
- Waiting for the Regional Director's order (filed via E-CHNG Part F after approval).
- Filing the certified order within 30 days of receipt.
This is one of the longest MCA compliance processes, often taking 3 to 6 months from start to finish.
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Get Expert HelpPart E: Application to Regional Director (Replaces RD-1)
E-CHNG Part E consolidates all applications that are routed through the Regional Director's office. RD-1 was a general-purpose form used for matters beyond registered office shifts, including applications under Section 14 (alteration of articles), Section 16 (rectification of name), and other provisions that require Regional Director intervention.
By housing this within E-CHNG, MCA creates a direct link between the application (Part E) and the resulting order (Part F). Previously, RD-1 and INC-28 were separate forms with no structural connection, and tracking the application-to-order chain required manual cross-referencing of SRN numbers.
Part F: Order of Regional Director or Central Government (Replaces INC-28)
E-CHNG Part F is where the company files the certified copy of the Regional Director's or Central Government's order. This is the final step in any process that involves Part D (interstate shift) or Part E (RD application).
The filing deadline remains 30 days from the date of receipt of the order. Late filing attracts additional fees under the Companies (Registration Offices and Fees) Rules, 2014, with the penalty starting at 2x the normal fee and escalating for delays beyond 270 days.
E-CON Form: Detailed Breakdown of Parts A Through E
E-CON stands for "Electronic Conversion" and consolidates all company conversion filings into a single modular form. Every type of company conversion under the Companies Act, 2013, from public-to-private to OPC conversion, now has a designated part within E-CON.
Part A: Public Company to Private Company Conversion (Replaces INC-18)
E-CON Part A replaces INC-18, the application form for converting a public limited company into a private limited company. This conversion requires:
- A special resolution under Section 14 of the Companies Act, 2013.
- Application to the National Company Law Tribunal (NCLT) for approval.
- Alteration of the Articles of Association to include restrictions on share transfer, member cap of 200, and prohibition of public invitations for shares.
After the NCLT order is received, the company files E-CON Part B to intimate the Registrar.
Part B: Intimation to Registrar of Conversion Approval (Replaces INC-20)
E-CON Part B replaces INC-20. Once the NCLT or the competent authority approves the conversion (under Part A), the company must file Part B with the Registrar of Companies within 15 days of receiving the order. This intimation triggers the ROC to update the company's registration records, CIN category, and compliance calendar.
Part C: OPC Conversion (Replaces INC-6)
E-CON Part C handles conversions involving One Person Companies. Under Section 18 read with Rule 7 of the Companies (Incorporation) Rules, 2014, an OPC must convert into a Private Limited Company or Public Company when:
- Paid-up share capital exceeds ₹50 lakh.
- Average annual turnover of the preceding 3 financial years exceeds ₹2 crore.
The OPC has 6 months from the date of exceeding the threshold to complete the conversion. E-CON Part C replaces INC-6 for this mandatory conversion filing. For more on OPC structure and thresholds, visit our One Person Company registration page.
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Start OPC ConversionPart D: Conversion of Already Registered Companies (Replaces INC-27)
E-CON Part D addresses companies that were registered under the Companies Act, 1956 or other previous legislation and need to convert or re-register under the Companies Act, 2013. This was previously handled by INC-27 under Part XXI of the Companies Act, 2013.
The new INC-11D certificate form works in conjunction with E-CON Part D. When a company files for Part XXI conversion, the practicing professional certifies the filing through INC-11D, which serves as the compliance certificate for the conversion.
Part E: Section 8 Company Conversions (Replaces INC-18/INC-20 for Section 8)
E-CON Part E is specifically designed for Section 8 company conversions. Previously, Section 8 conversion applications and intimations used the same INC-18 and INC-20 forms as regular public-to-private conversions, which created confusion since Section 8 companies have distinct requirements:
- Section 8 companies cannot distribute dividends to members.
- Conversion requires NCLT approval, not just a special resolution.
- The company must demonstrate that the charitable or social purpose can no longer be served.
By giving Section 8 conversions their own dedicated part (Part E), MCA separates these filings from standard conversions and enables form-level validation specific to Section 8 requirements.
New INC-11D Certificate: What It Is and When to Use It
INC-11D is the only entirely new form in this notification. It does not replace any existing form. It is a certificate that a practicing professional (Company Secretary or Chartered Accountant) must issue for Part XXI conversions under the Companies Act, 2013.
| Attribute | INC-11D Details |
|---|---|
| Form Type | Certificate (practitioner-issued) |
| Replaces | None (new form) |
| Used With | E-CON Part D (Part XXI conversions) |
| Issued By | Practicing CS, CA, or Cost Accountant in whole-time practice |
| Legal Basis | Part XXI, Companies Act, 2013 |
| Notified Under | Companies (Incorporation) Amendment Rules, 2026 |
INC-11D adds a practitioner accountability layer to Part XXI conversions. The certifying professional confirms that the company has complied with all conversion prerequisites, that the financial statements are in order, and that the proposed conversion does not violate any statutory provision.
When to Use Which Form: A Practical Decision Guide
With 11 parts spread across 2 forms plus a separate certificate, choosing the right form requires matching your specific action to the correct part. Here is a scenario-based guide:
| What You Need to Do | Form and Part | Old Form | Key Requirement |
|---|---|---|---|
| Change company name | E-CHNG Part A | INC-24 | Special resolution + RUN approval |
| Shift office within same city/ROC | E-CHNG Part B | INC-22 | Board resolution + address proof |
| Verify registered office after incorporation | E-CHNG Part C | INC-22 | Within 30 days of incorporation |
| Move registered office to another state | E-CHNG Part D | INC-23 | Special resolution + RD approval |
| File application to Regional Director | E-CHNG Part E | RD-1 | Depends on section being invoked |
| File RD or Central Government order | E-CHNG Part F | INC-28 | Certified order copy + 30-day deadline |
| Convert public company to private | E-CON Part A | INC-18 | Special resolution + NCLT approval |
| Intimate Registrar of conversion approval | E-CON Part B | INC-20 | Within 15 days of order |
| Convert OPC to Private Limited | E-CON Part C | INC-6 | Capital > ₹50L or turnover > ₹2Cr |
| Convert company registered under old Act | E-CON Part D + INC-11D | INC-27 | Part XXI compliance + practitioner certificate |
| Convert Section 8 company | E-CON Part E | INC-18/INC-20 | NCLT approval required |
When filing E-CHNG Part D (interstate shift), you will also need to file E-CHNG Part E (RD application) and eventually E-CHNG Part F (RD order). Plan for all three parts as a single compliance project, not as three separate filings. The old workflow of INC-23 → RD-1 → INC-28 now becomes E-CHNG Part D → Part E → Part F.
Impact on MCA V3 Portal Filing
The MCA V3 portal is the exclusive digital interface for all company filings in India. Every form, fee payment, DSC attestation, and SRN generation happens on V3. So what changes when 9 forms collapse into 2?
Form selection changes: Instead of searching for "INC-22" or "INC-24" in the V3 portal's form directory, you will select "E-CHNG" and then choose the relevant part (A through F). The same applies to E-CON (Parts A through E). This is similar to how SPICe+ works with its Part A (name reservation) and Part B (incorporation) structure.
SRN format updates: Each part generates its own Service Request Number (SRN). Filing E-CHNG Part D and Part E for an interstate shift will produce 2 separate SRNs, which aligns with the current behavior where INC-23 and RD-1 generated separate SRNs.
Pre-fill and validation: MCA is expected to introduce cross-part pre-filling. If you file E-CHNG Part D (interstate shift), Parts E and F should auto-populate company details from Part D. This reduces data re-entry and lowers the error rate on linked filings.
DSC requirements: Digital Signature Certificate requirements remain unchanged. Director DSC and practicing professional DSC are required on the same parts as their predecessor forms. No new DSC requirements have been added.
Attachment handling: One area where the V3 portal update will matter is document attachments. Currently, each form has its own attachment checklist. For example, INC-22 requires address proof and a landlord NOC, while INC-23 requires newspaper advertisements and a creditor list. Under E-CHNG, the attachment requirements will be part-specific. Selecting Part B will trigger the INC-22 attachment checklist, while selecting Part D will trigger the INC-23 checklist. This conditional attachment logic already exists in SPICe+ and AGILE-PRO filings.
Is this a better system than filing 9 separate forms? For anyone who has ever filed INC-23, then RD-1, then INC-28 for a single interstate office shift, the answer is obvious.
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Talk to Our ExpertsWhat Changes for Chartered Accountants and Company Secretaries
If you are a practicing CA, CS, or Cost Accountant, the E-CHNG and E-CON consolidation directly affects your filing workflows, client advisories, and certification responsibilities.
Updated form certification: The DSC and certification blocks on E-CHNG and E-CON will have a part-specific format. Certifying E-CHNG Part A (name change) requires confirming compliance with Section 13 and the name change provisions, while certifying E-CON Part C (OPC conversion) requires confirming the paid-up capital and turnover thresholds under Rule 7.
Client communication: Clients who previously knew the form by name ("please file INC-22 for my office change") will need to be informed about the new form nomenclature. A simple mapping document shared with clients will reduce confusion during the transition. How will your firm handle this communication?
INC-11D certification: If your practice includes Part XXI conversion work, INC-11D adds a new certification responsibility. The practicing professional must verify compliance with all Part XXI prerequisites before issuing the certificate. This is not a checkbox exercise; it carries personal liability under Section 448 of the Companies Act, 2013 for false certification.
Practice management software: If you use software that auto-generates MCA forms, the templates for INC-22, INC-23, INC-24, INC-28, and RD-1 will become obsolete. Confirm with your vendor that E-CHNG and E-CON templates will be available before the gazette notification date.
Under Section 448 of the Companies Act, 2013, a professional who certifies a false or misleading form faces imprisonment up to 6 months and a fine up to ₹1 lakh. The new part-based structure does not change this liability. If anything, the INC-11D certificate adds a new certification layer for Part XXI conversions.
Timeline and Transition Period
The transition from old forms to E-CHNG and E-CON will follow MCA's standard rule-making process. Here is what to expect:
- April 8, 2026: MCA publishes the draft Companies (Incorporation) Amendment Rules, 2026, including E-CHNG, E-CON, and INC-11D form specifications.
- May 9, 2026: Comment deadline for stakeholder feedback on the draft rules.
- Post-May 2026: MCA reviews comments and finalizes the rules. This typically takes 30 to 60 days.
- Gazette notification: The final rules are published in the Official Gazette. The new forms become legally effective from this date.
- V3 portal update: MCA updates the V3 portal to include E-CHNG (Parts A-F) and E-CON (Parts A-E). Old forms are deactivated.
- Transition window: Based on past MCA transitions (like the SPICe+ rollout in February 2020), a 15 to 30-day parallel period where both old and new forms are accepted is expected.
What should you do right now? If you have any pending filings for INC-22, INC-23, INC-24, or INC-28, complete them before the gazette notification date. Filings submitted before the effective date will be processed under the old rules. Do not wait for a last-minute rush, especially for interstate office shifts (INC-23 / E-CHNG Part D) that involve Regional Director processing timelines of 3 to 6 months.
- Complete all pending INC-22, INC-23, INC-24, and RD-1 filings before the gazette date.
- Update your internal compliance calendar to reference E-CHNG and E-CON parts.
- Brief your CS or CA on the new form structure.
- Confirm your practice management or compliance software vendor has an update roadmap.
E-CHNG vs E-CON: Quick Comparison
How do these two forms differ in scope, purpose, and application? Here is a side-by-side view:
| Parameter | E-CHNG | E-CON |
|---|---|---|
| Full Name | Electronic Change | Electronic Conversion |
| Number of Parts | 6 (A through F) | 5 (A through E) |
| Old Forms Replaced | INC-22, INC-23, INC-24, INC-28, RD-1 | INC-6, INC-18, INC-20, INC-27 |
| Scope | Post-incorporation changes (name, address, RD applications) | Company type conversions (public/private, OPC, Section 8, Part XXI) |
| Companion Certificate | None | INC-11D (for Part D only) |
| Requires RD/NCLT Approval | Parts D, E, F (Regional Director) | Parts A, E (NCLT) |
| Applicable To | All companies under Companies Act, 2013 | All companies under Companies Act, 2013 |
| LLP Applicability | Not applicable | Not applicable |
Summary
The MCA's consolidation of 9 forms into E-CHNG (Parts A-F) and E-CON (Parts A-E), along with the new INC-11D certificate, is the most significant structural change to company change and conversion filings since the introduction of SPICe+ in 2020. The public notice dated April 8, 2026, under Policy Reference CL-V Section, Policy-01/2/2025-CL-V-MCA-Part(2), sets a May 9, 2026 comment deadline. Once published in the Official Gazette, the old forms (INC-6, INC-18, INC-20, INC-22, INC-23, INC-24, INC-27, INC-28, and RD-1) will be permanently deactivated on the MCA V3 portal.
For companies, the action is clear: complete any pending filings on old forms before the gazette date, update your compliance workflows to reference the new E-CHNG and E-CON part numbers, and ensure your CS or CA is prepared for the transition. For professionals, map your existing form templates to the new structure, prepare client advisories, and watch for the V3 portal update notification.
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