What Is Significant Beneficial Owner (SBO) Declaration?
Significant Beneficial Owner (SBO) is an individual who, acting alone or together with other individuals or through one or more body corporates or in any other manner, holds or controls, directly or indirectly, not less than 10% of the shares, voting rights, or right to receive dividend or distribution in a reporting company.
The SBO disclosure framework under Section 90 of the Companies Act, 2013 and the Companies (Significant Beneficial Owners) Rules, 2018 is designed to identify the "real" natural persons who ultimately own or control a company, even if they hold their interest through layers of holding companies, trusts, partnerships, LLPs, or other intermediate entities.
🔍 Key Features of SBO Disclosure
Transparency in Ultimate Ownership
SBO rules mandate disclosure of the ultimate individual(s) who benefit from the company's shares, profits, or control — cutting through complex ownership structures to reveal the 'real owners'.
10% Threshold (Three Parameters)
An individual is an SBO if they hold or control ≥10% of: (a) shares (by number or value), (b) voting rights, or (c) right to receive dividend/distribution in a financial year — calculated directly or indirectly.
Two-Step Disclosure Process
Step 1: The individual SBO files Form BEN-1 (declaration) with the company. Step 2: The company files Form BEN-2 with the Registrar of Companies within 30 days of receiving BEN-1, disclosing all SBOs.
Applies to All Reporting Companies
Every company (except government companies and wholly-owned subsidiaries of foreign companies) is a 'reporting company' under the SBO Rules and must identify and declare SBOs, if any.
Indirect Holding Through Body Corporates
If a body corporate (company, LLP, trust, partnership, etc.) holds shares in the reporting company, the company must trace through the ownership chain to identify the ultimate individual(s) holding ≥10% indirectly.
Severe Penalties for Non-Compliance
Non-filing of BEN-1 by the individual attracts penalties of ₹1 lakh to ₹10 lakh + imprisonment + suspension of shareholder rights. Non-filing of BEN-2 by the company attracts ₹1 lakh to ₹10 lakh on the company and ₹50,000 to ₹2 lakh on officers.
✅ Who Qualifies as an SBO? (Three Criteria)
Criterion 1: Shareholding ≥ 10%
An individual holds or controls, directly or indirectly, 10% or more of the shares (by number or value) of the reporting company.
Example: Person A holds 100% of Company X, which holds 15% of Company Y → Person A indirectly holds 15% of Company Y → Person A is an SBO of Company Y.
Criterion 2: Voting Rights ≥ 10%
An individual holds or controls 10% or more of the voting rights in the reporting company, directly or indirectly (through body corporates, voting agreements, proxies, etc.).
Example: Person B holds 8% shares directly + 3% through a trust = 11% voting rights → Person B is an SBO.
Criterion 3: Right to Receive Dividend/Distribution ≥ 10%
An individual has the right to receive or participate in 10% or more of the dividend or any other distribution payable in a financial year, directly or indirectly.
Example: Person C is the sole beneficiary of a trust that holds 12% shares in Company Z → Person C has a 12% right to dividend → Person C is an SBO.
Note: If an individual meets ANY ONE of the above criteria (≥10% in shares, voting rights, or dividend/distribution rights), they are a Significant Beneficial Owner and must file BEN-1.
🏢 What Are "Reporting Companies"?
✓ All Companies (With Limited Exceptions)
Every company incorporated in India — private limited, public limited, one-person companies, Section 8 companies — is a 'reporting company' under the SBO Rules and must comply with SBO disclosure requirements.
✗ Government Companies
Companies in which 51% or more of the paid-up capital is held by the Central Government, State Government(s), or both, are exempted from SBO disclosure norms.
✗ Wholly-Owned Subsidiaries of Foreign Companies
Indian companies that are 100% subsidiaries of a foreign company registered in a country notified by the Central Government (countries with adequate SBO disclosure laws) are exempted — as of 2025, no such countries have been notified, so this exemption is currently not applicable.
Practical Implication: Unless your company is a government company, you must assume it is a reporting company and comply with SBO disclosure if you have layered or indirect shareholding.
🔗 What Is "Indirect Holding" for SBO Purposes?
Indirect holding means holding shares, voting rights, or dividend rights in the reporting company through one or more intermediate entities — body corporates, trusts, partnerships, LLPs, or any other entity or arrangement.
Examples of Indirect Holding:
- • Person A → 100% of Company X → Company X holds 20% of Company Y → Person A indirectly holds 20% of Company Y
- • Person B → 50% of Trust T → Trust T holds 25% of Company Z → Person B indirectly holds 12.5% of Company Z
- • Person C → 60% of LLP L → LLP L holds 18% of Company M → Person C indirectly holds 10.8% of Company M
- • Multi-layer: Person D → 100% of Holdco 1 → Holdco 1 holds 80% of Holdco 2 → Holdco 2 holds 15% of Company N → Person D indirectly holds 12% (80% × 15%) of Company N
Key Rule: The company must trace the ownership chain through all intermediate entities until it reaches the ultimate individual(s), and if the ultimate individual's indirect holding is ≥10%, they are an SBO.
⚠️ Consequences of Non-Compliance
- →Penalty on Individual (SBO): ₹1 lakh to ₹10 lakh + imprisonment up to 1 year for failure to file BEN-1 or providing false information (Section 90(10)).
- →Suspension of Shareholder Rights: Shares or voting rights in respect of which the individual is an SBO may be suspended — no voting, no dividend, no transfer — until BEN-1 is filed (Section 90(6)).
- →Penalty on Company: ₹1 lakh to ₹10 lakh on the company for failure to file BEN-2 or failure to take adequate steps to identify SBOs (Section 90(11)).
- →Penalty on Officers in Default: Every director, company secretary, and KMP liable to ₹50,000 to ₹2 lakh + imprisonment up to 6 months for company's non-compliance (Section 90(11)).
- →ROC Action & Prosecution: The ROC may initiate prosecution proceedings, and repeated non-compliance can lead to director disqualification or even strike-off action.
- →Due Diligence Impact: Lenders, investors, and acquirers conducting due diligence will flag SBO non-compliance as a major red flag, potentially derailing transactions.
🎯 When Must Companies File BEN-2?
Initial Identification (One-Time)
Every reporting company must, as a one-time exercise, identify all existing SBOs in its shareholding as of the date the SBO Rules came into force (13th June 2018 for most companies) and file BEN-2 for all such SBOs.
On Receipt of BEN-1 (30-Day Deadline)
Whenever the company receives a BEN-1 declaration from an individual (existing or new SBO), it must file BEN-2 with the Registrar within 30 days of receipt of BEN-1.
On Changes in SBO Details
If there is any change in the particulars of an existing SBO (e.g., change in address, PAN, percentage of holding), the SBO must file a revised BEN-1 within 30 days of the change, and the company must file BEN-2 within 30 days of receiving the revised BEN-1.
On Cessation of SBO Status
If an individual ceases to be an SBO (e.g., their indirect holding falls below 10%), they must inform the company, and the company must file BEN-2 updating the cessation within 30 days.
SBO Identification & BEN-2 Filing Process
Complete SBO compliance process — from ownership structure analysis to BEN-2 e-filing:
Shareholding Pattern & Ownership Structure Mapping
2-3 daysObtain the company's current shareholding pattern (list of all shareholders with their shareholding percentage, voting rights, and dividend rights). For each shareholder that is a body corporate (company, LLP, trust, partnership, etc.), obtain their shareholding/ownership structure to identify the ultimate individual(s) behind them. Create an ownership structure chart/diagram showing the layers of shareholding — e.g., Individual A → 100% of Holdco X → Holdco X holds 20% of Reporting Company Y. This mapping is critical for determining who the SBOs are and must be done accurately to avoid missing any SBOs.
SBO Threshold Analysis (10% Test)
2-3 days (complex structures may take longer)For each ultimate individual identified in the ownership structure, calculate their indirect holding in the reporting company by multiplying the ownership percentages across the chain. Example: Individual A holds 100% of Holdco X, which holds 15% of Company Y → A's indirect holding = 100% × 15% = 15% → A is an SBO. Apply the 10% threshold test to THREE parameters: (a) Shareholding (by number or value): ≥10%? (b) Voting rights: ≥10%? (c) Right to receive dividend/distribution: ≥10%? If ANY ONE parameter is ≥10%, the individual is an SBO. Include individuals who, acting together (e.g., family members, persons acting in concert under shareholders' agreements), collectively hold ≥10%. Prepare a list of all identified SBOs with their holding percentages and supporting calculations.
Notice to Individuals & BEN-1 Declaration Collection
30 days (statutory time for individual to respond)Once SBOs are identified, the company must send a written notice to each individual (via registered post or email with acknowledgment) informing them that they qualify as an SBO and requesting them to file Form BEN-1 (declaration by the individual to the company) within 30 days of receipt of the notice. Form BEN-1 requires the individual's details: name, father's name, date of birth, nationality, PAN, Aadhaar, residential address, email, mobile number, details of shares/voting rights/dividend rights held indirectly, details of body corporates/entities through which the holding is indirect, and a declaration that the information provided is true. The individual must sign BEN-1 and submit it to the company along with copies of PAN card, Aadhaar card, and passport (if foreign national). Taxvio can assist in drafting the notice to individuals and coordinating the BEN-1 collection process.
Verification of BEN-1 Declarations
1-2 days per BEN-1Upon receipt of BEN-1 from each SBO, verify the details provided by the individual against the company's shareholding records and ownership structure analysis. Check for: (a) accuracy of shareholding/voting/dividend percentage calculations, (b) correctness of PAN, Aadhaar, and other identity documents, (c) completeness of details of intermediate entities (body corporates) through which the holding is indirect, and (d) signature and date of the BEN-1 form. If there are discrepancies or missing information, request the individual to file a revised BEN-1. Ensure all BEN-1s are received within the 30-day deadline (or as extended by agreement) to allow timely BEN-2 filing by the company.
Preparation of Form BEN-2
2-3 days (complex structures with multiple SBOs may take longer)Form BEN-2 (Return of Significant Beneficial Owner) is filed by the company with the Registrar of Companies to declare all SBOs. The form requires: (a) CIN of the reporting company, (b) details of each SBO: name, father's name, nationality, date of birth, PAN, Aadhaar number, address, email, mobile, (c) details of shares/voting rights/dividend rights held by the SBO (percentage and absolute numbers), (d) details of the body corporate(s) or entity(ies) through which the individual holds the beneficial interest (name, CIN/registration number, country of incorporation, percentage of holding at each layer), (e) date of receipt of BEN-1 from the individual, (f) attachments: copies of BEN-1 declarations, PAN cards, Aadhaar cards, and supporting documents for ownership structure (shareholding certificates, extracts from statutory registers of intermediate entities). Prepare BEN-2 carefully, ensuring consistency between the BEN-1 declarations and the BEN-2 disclosures — errors can lead to ROC queries or penalties.
Digital Signature & E-Filing of BEN-2
1-2 hours (DSC signing & e-filing)Form BEN-2 must be digitally signed by a director of the company (using their DSC). Pre-fill the form on the MCA portal, attach all required documents (BEN-1s, PAN/Aadhaar copies, ownership structure documents), and submit the form. Pay the requisite government fee (₹5,000 as of FY 2025-26 for standard filing; additional fees for delayed filing). Upon successful submission, MCA generates a Service Request Number (SRN) — save this for tracking. BEN-2 must be filed within 30 days of the date of receipt of BEN-1 from the individual(s) — missing this deadline attracts penalties.
MCA Processing & Acknowledgment
1-2 working daysThe MCA portal processes the BEN-2 e-form. If the form is complete and accurate, MCA issues an acknowledgment (typically within 1-2 working days). Download the acknowledgment from the MCA portal and save it in the company's statutory records. The acknowledgment is the official proof that the SBO disclosure has been filed with the Registrar of Companies. If the ROC has queries or requires clarifications (e.g., discrepancies in shareholding calculations, missing documents, incorrect PAN/Aadhaar), respond promptly via the MCA portal to avoid rejection or penalties.
Maintenance of Register of Significant Beneficial Owners
Within 7 days of BEN-2 acknowledgmentEvery reporting company must maintain a Register of Significant Beneficial Owners in Form BEN-3, recording the details of all SBOs as disclosed in the BEN-2 filings. The register must be kept at the company's registered office and must be open for inspection by members (shareholders) of the company during business hours. Update the register whenever: (a) a new SBO is identified and BEN-2 is filed, (b) an existing SBO's details change (and revised BEN-1/BEN-2 is filed), or (c) an individual ceases to be an SBO (and BEN-2 is filed updating the cessation). Taxvio provides templates for the Register of SBOs and assists in maintaining it as part of the standard statutory registers package.
Annual Review & Update of SBO Status
Ongoing (annual review)At least once every financial year (ideally at the time of annual return preparation), review the company's shareholding pattern and ownership structure to check for any changes that may affect SBO status: (a) new shareholders who may be holding indirectly through body corporates, (b) changes in the shareholding of intermediate entities that may increase or decrease an individual's indirect holding, (c) individuals whose indirect holding has increased to ≥10% (becoming new SBOs), or (d) individuals whose indirect holding has fallen below 10% (ceasing to be SBOs). If any changes are identified, request the affected individuals to file BEN-1 (or inform the company of cessation), and file BEN-2 within 30 days. Maintain documentation of this annual review for compliance records and ROC inspection.
Handling Non-Responsive Individuals & Section 90(4) Notice
60+ days (if individual is non-responsive)If the company sends a notice to an individual whom it believes is an SBO, but the individual does not respond or file BEN-1 within 30 days, the company must take additional steps: (a) Send a SECOND notice via registered post with acknowledgment due, reiterating the requirement to file BEN-1 and warning of the consequences (penalty, rights suspension). (b) If the individual still does not respond within 30 days of the second notice, the company may file an application with the National Company Law Tribunal (NCLT) under Section 90(7) seeking an order to direct the individual to file BEN-1 and/or to suspend the rights attached to the shares in respect of which the individual is an SBO (no voting, no dividend, no transfer). (c) In the meantime, the company should file BEN-2 to the extent of the information it has (based on the shareholding structure analysis), noting that the individual has not filed BEN-1, and maintain records of all notices sent and follow-up actions taken. This protects the company from being penalized for the individual's non-compliance. Taxvio provides legal coordination and NCLT filing support for such cases.
✅Total Timeline
5-7 working days for a straightforward case (company with 1-2 layers of shareholding and 1-2 SBOs), assuming prompt receipt of BEN-1 declarations from the individuals. For complex multi-layered structures or companies with multiple SBOs, the process can take 2-4 weeks. Breakdown: ownership structure mapping & threshold analysis (2-3 days) + notice to individuals & BEN-1 collection (30 days statutory time, may be shorter if individuals are cooperative) + BEN-1 verification & BEN-2 preparation (2-3 days) + BEN-2 e-filing & acknowledgment (1-2 days). Critical deadline: File BEN-2 within 30 days of receipt of BEN-1 to avoid penalties. Taxvio expedites the process through proactive individual coordination and parallel processing of BEN-1 verifications.
Documents Required for SBO & BEN-2 Filing
From the Company
- ✓Certificate of Incorporation (CIN for verification)
- ✓Current shareholding pattern (list of all shareholders with percentage)
- ✓Register of Members extract (as on date)
- ✓Details of body corporate shareholders (name, CIN/registration number, registered office address)
- ✓Shareholding structure of each body corporate shareholder (one level up or until ultimate individual is identified)
- ✓MOA & AOA (for understanding voting rights and dividend rights provisions)
- ✓Shareholders' agreements or voting agreements (if any, affecting control/voting)
- ✓DSC of at least one director (for digitally signing BEN-2)
From Each SBO (Individual)
- ✓Form BEN-1 (declaration by the individual to the company, signed and dated)
- ✓PAN card (mandatory — Indian nationals and eligible foreign nationals)
- ✓Aadhaar card (for Indian nationals) or Passport (for foreign nationals)
- ✓Proof of residential address (utility bill, bank statement, passport, Aadhaar — <2 months old)
- ✓Email ID and mobile number (for MCA communication)
- ✓Details of body corporate(s) through which the individual holds the beneficial interest (name, CIN, percentage of holding at each layer)
- ✓Supporting documents for indirect holding (share certificates, extracts from Register of Members of intermediate entities, trust deeds if applicable)
For Intermediate Entities (Body Corporates)
- ✓Certificate of Incorporation or registration certificate
- ✓Shareholding pattern or ownership structure (showing who holds shares in the intermediate entity)
- ✓Register of Members extract (if the intermediate entity is a company)
- ✓Partnership deed (if the intermediate entity is a partnership/LLP)
- ✓Trust deed and details of beneficiaries (if the intermediate entity is a trust)
- ✓Board resolution or consent (if the intermediate entity needs to provide information/documents to the reporting company)
For BEN-2 Filing (MCA Attachments)
- ✓All BEN-1 declarations received from SBOs (scanned PDF copies)
- ✓PAN cards of all SBOs (scanned copies)
- ✓Aadhaar cards (or passports for foreign nationals) of all SBOs (scanned copies)
- ✓Ownership structure chart/diagram (visual representation of the shareholding layers)
- ✓Shareholding certificates or extracts from Register of Members of intermediate entities (supporting the indirect holding calculations)
- ✓Board resolution of the reporting company authorizing the filing of BEN-2 (recommended, though not strictly mandatory)
📝 Additional Information Required for SBO Analysis
- •Total number of shares issued by the reporting company (for calculating percentages)
- •Total voting rights in the company (may differ from shareholding if there are preference shares or differential voting rights)
- •Dividend distribution policy or patterns (for calculating right to receive dividend percentage)
- •Details of any shareholders' agreements, voting agreements, or family arrangements affecting control
- •Information on whether any shareholders are 'acting in concert' (persons who agree to act together to acquire or exercise control)
- •Timeline of shareholding changes in the past 12 months (to identify when SBO status arose or ceased)
Common Mistakes in SBO & BEN-2 Filing
SBO compliance involves complex ownership analysis — avoid these critical errors:
Incomplete Ownership Structure Mapping
⚠️ Problem
Failing to trace the ownership chain all the way to the ultimate individual(s), especially in multi-layered structures with 3 or more levels of body corporates, trusts, or partnerships. Companies often stop at the immediate shareholder (e.g., 'Holdco X holds 20%') without identifying who holds Holdco X, thus missing the SBO entirely. This is the most common reason for non-identification of SBOs and consequent penalties.
✅ Solution
For EVERY body corporate shareholder, obtain their shareholding structure and continue tracing upwards until you reach individual(s). If Holdco X is owned by Holdco Y, find out who owns Holdco Y, and so on, until you reach natural persons. Create a visual ownership chart/diagram showing all layers. If an intermediate entity refuses to provide information, send a formal notice under Section 90(3) requiring them to provide the information within 30 days — failure to provide can result in penalties on that entity. Taxvio uses professional ownership structure mapping tools and templates to ensure no SBOs are missed.
Incorrect Calculation of Indirect Holding Percentage
⚠️ Problem
Miscalculating the indirect holding percentage, especially in complex structures. For example: Person A holds 50% of Holdco X, and Holdco X holds 25% of Company Y — the correct indirect holding of Person A in Company Y is 50% × 25% = 12.5%, NOT 25%. Errors in multiplication across layers, or failing to account for partial ownership at intermediate levels, lead to incorrect SBO determinations (either missing SBOs or wrongly identifying non-SBOs).
✅ Solution
Use a systematic calculation method: multiply the ownership percentages at each layer to arrive at the ultimate indirect holding. Example: A → 60% of B → B holds 80% of C → C holds 15% of Reporting Company → A's indirect holding = 60% × 80% × 15% = 7.2% (A is NOT an SBO in this case). Document all calculations in a spreadsheet or ownership analysis report. For companies with complex structures, engage a CA or CS to perform the calculations and certify the accuracy. Taxvio provides detailed SBO threshold analysis reports with calculations for all individuals in the ownership chain.
Not Considering All Three Parameters (Shares, Voting, Dividend)
⚠️ Problem
Checking only the shareholding percentage (e.g., 'Person B holds 8% indirectly, so not an SBO') without considering whether the person holds ≥10% of voting rights or dividend rights separately. In companies with preference shares, differential voting rights, or special dividend distribution arrangements, an individual may be below 10% in shareholding but above 10% in voting or dividend rights, thus qualifying as an SBO. Missing this leads to non-compliance.
✅ Solution
Apply the 10% threshold test to ALL THREE parameters for each individual: (1) Shareholding (number or value of shares), (2) Voting rights (total votes the individual can exercise, directly or indirectly), (3) Right to receive dividend/distribution in a financial year (percentage of total dividend payable). If the individual is ≥10% in ANY ONE parameter, they are an SBO. Review the company's MOA, AOA, shareholders' agreements, and any special rights attached to preference shares or founder shares to accurately determine voting and dividend rights. Taxvio's SBO analysis includes a three-parameter checklist for every identified individual.
Delayed or Missing BEN-1 Collection from Individuals
⚠️ Problem
Identifying the SBOs correctly but failing to obtain BEN-1 declarations from them in a timely manner (or at all). Individuals may be unresponsive, unaware of their obligations, or unwilling to disclose their status. If the company files BEN-2 without receiving BEN-1 from the individual, or misses the 30-day BEN-2 filing deadline due to delays in BEN-1 collection, both the company and the individual can be penalized.
✅ Solution
Immediately upon identifying an individual as an SBO, send them a formal written notice (via registered post + email) explaining their SBO status, their obligation to file BEN-1 within 30 days, and the consequences of non-filing (penalties, rights suspension). Provide the individual with a draft BEN-1 form pre-filled with the company's knowledge, along with instructions on how to complete and submit it. Follow up via phone/email after 15 days if BEN-1 is not received. If the individual is still non-responsive after 30 days, send a second notice and consider NCLT proceedings under Section 90(7) to compel compliance. Keep records of all notices and follow-ups to demonstrate the company's good-faith efforts. Taxvio handles the entire BEN-1 collection process, including drafting notices, coordinating with individuals, and following up for timely submission.
Filing BEN-2 After the 30-Day Deadline
⚠️ Problem
Filing Form BEN-2 more than 30 days after receiving BEN-1 from the individual. This is a strict statutory deadline under Rule 6(1) of the SBO Rules, and delayed filing attracts automatic penalties on the company (₹1 lakh to ₹10 lakh) and on every officer in default (₹50,000 to ₹2 lakh). Even if the delay is due to the individual's late submission of BEN-1, the company is still liable once it receives BEN-1.
✅ Solution
Maintain a tracker/register recording the date of receipt of each BEN-1 and the corresponding BEN-2 filing deadline (receipt date + 30 days). Set calendar reminders for 7 days before the deadline to prepare and file BEN-2. If you anticipate difficulty meeting the deadline (e.g., pending document verification, DSC issues), file BEN-2 on or before the 30th day even if some minor details are pending, and file a revised BEN-2 later if needed. Taxvio's compliance calendar system automatically tracks BEN-1 receipt dates and BEN-2 deadlines, ensuring on-time filing.
Not Maintaining or Updating the Register of SBOs (Form BEN-3)
⚠️ Problem
Failing to maintain the Register of Significant Beneficial Owners in Form BEN-3 at the registered office, or failing to update it when new SBOs are identified, existing SBO details change, or individuals cease to be SBOs. The register is a statutory requirement under Rule 7, and its absence or non-maintenance can lead to penalties during ROC inspections or member inspections (shareholders have the right to inspect the SBO register).
✅ Solution
Immediately after each BEN-2 filing, update the Register of SBOs (Form BEN-3) with the details of the SBO(s) disclosed in that BEN-2. Maintain the register in physical or electronic form at the registered office, and ensure it is accessible for inspection by members during business hours (9 AM to 6 PM on working days, or as per company policy). When an SBO's details change or they cease to be an SBO, update the register accordingly within 7 days of filing the updated BEN-2. Taxvio provides a template for Form BEN-3 and maintains the register as part of the statutory registers package, with automatic updates synchronized with BEN-2 filings.
SBO & BEN-2 Filing Packages
Comprehensive SBO compliance packages for companies with layered ownership:
Basic
₹4,999
One-time fee
Included Services
- ✓Shareholding pattern analysis (single-layer structure)
- ✓SBO threshold calculation (up to 2 individuals)
- ✓Notice to individuals for BEN-1
- ✓BEN-1 verification & collection support
- ✓Form BEN-2 preparation & e-filing (single filing)
- ✓MCA fee payment (₹5,000 included)
- ✓Acknowledgment download & delivery
- ✓Email support
Not Included
- ✗Multi-layer ownership structures not included (>2 layers)
- ✗No Register of SBOs maintenance
- ✗No annual SBO review
Ideal For
Companies with simple shareholding structures (1-2 body corporate shareholders, 1-2 SBOs)
Standard
₹9,999
One-time fee
Included Services
- ✓Everything in Basic
- ✓Multi-layer ownership structure mapping (up to 4 layers)
- ✓Comprehensive SBO threshold analysis (up to 5 individuals)
- ✓BEN-1 collection coordination (multiple SBOs)
- ✓Multiple BEN-2 filings (if SBOs file BEN-1 at different times)
- ✓Register of Significant Beneficial Owners (Form BEN-3) setup
- ✓Statutory register update
- ✓Priority WhatsApp + email support
Not Included
- ✗Annual SBO review offered as add-on
Ideal For
Companies with layered shareholding (holding companies, trusts, partnerships in the chain)
Complete
₹14,999
One-time fee
Included Services
- ✓Everything in Standard
- ✓Complex multi-layer structure analysis (5+ layers, 10+ entities)
- ✓Comprehensive ownership chart/diagram preparation
- ✓Legal notice drafting for non-responsive individuals
- ✓NCLT proceedings support (if required under Section 90(7))
- ✓Annual SBO review & update (included for 1 year)
- ✓Register of SBOs maintenance (ongoing for 1 year)
- ✓Dedicated CA + CS team with year-round support
Ideal For
Companies with highly complex ownership structures, offshore entities, or multiple trusts/partnerships
💼 Add-On Services (Optional)
Annual SBO Review & Update
₹4,999/year
Annual review of shareholding changes, updated SBO analysis, revised BEN-2 filing if needed
Additional BEN-2 Filing
₹2,999/filing
For new SBOs identified mid-year or changes in existing SBO details
Register of SBOs Maintenance
₹1,999/year
Ongoing maintenance and updating of Form BEN-3 register at registered office
NCLT Proceedings Support
₹19,999+
Legal coordination and filing for non-responsive SBOs under Section 90(7)
Offshore Entity Tracing
₹9,999+
For identifying SBOs behind foreign holding companies or offshore trusts
DSC for Director
₹1,499/DSC
Class 3 DSC procurement for BEN-2 digital signing
What Our Clients Say
"Our company had 3 layers of holding companies, and we had no idea who our SBOs were. Taxvio mapped our entire ownership structure, identified 4 SBOs across different branches, coordinated BEN-1 collection from all of them, and filed BEN-2 within the deadline. They even maintained our Register of SBOs. Saved us from massive penalties."
Amit Gupta, Director
TechVentures Pvt Ltd
Noida, UP
"We had two SBOs who were non-responsive to our notices. Taxvio drafted formal legal notices, coordinated follow-ups, and when one SBO still didn't respond, they helped us file an NCLT application under Section 90(7). The NCLT order compelled the SBO to file BEN-1, and we were compliant. Professional and persistent service."
Neha Sharma, Company Secretary
Global Infra Holdings Pvt Ltd
Gurgaon, HR
"Our ownership structure involved a family trust with 6 beneficiaries, and we couldn't figure out if all of them were SBOs or just some. Taxvio did a detailed threshold analysis, calculated indirect holdings for each beneficiary, and correctly identified only 2 of them as SBOs (≥10% each). Filed BEN-2 accurately with zero ROC queries. Highly recommended for complex trust structures."
Rajiv Mehta, CFO
Heritage Estates Pvt Ltd
Mumbai, MH
SBO & BEN-2 Filing Services Across India
Taxvio is based in Khatauli, Muzaffarnagar, UP and provides online SBO identification and BEN-2 filing services for companies with layered shareholding across Meerut, Noida, Delhi NCR, Mumbai, Pune, Ahmedabad, Surat, and all cities in India. Complete remote handling with ownership structure analysis, BEN-1 coordination, and MCA filing.
Frequently Asked Questions — SBO & BEN-2 Filing
Do all companies need to identify and declare SBOs?+
What if our company has only foreign body corporate shareholders — do SBO rules still apply?+
Can a body corporate (company, trust, partnership, LLP) be an SBO?+
What is 'acting together' or 'persons acting in concert' for SBO purposes?+
How do we handle trusts in the ownership structure for SBO identification?+
Is there any grace period or exemption for companies incorporated before the SBO Rules came into force?+
Beneficial Ownership Transparency
Identify Your SBOs & File BEN-2 — Stay Compliant
Get complete ownership structure analysis, SBO threshold calculation, BEN-1 collection support, and BEN-2 filing handled by experts. Avoid penalties up to ₹10 lakh and shareholder rights suspension. Starting ₹4,999 with CA & CS team.