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Compliance

SBO Compliance Checker

Virtual AuditorPublished: 23 Mar 2026🕒 1 min readLast updated: 14 Aug 2026

Quick Answer

The SBO Compliance Checker identifies Significant Beneficial Owners as mandated by Section 90 of the Companies Act, 2013. By inputting shareholder details, users can determine who qualifies as an SBO and ascertain the necessary compliance obligations regarding BEN-1 and BEN-2 filing requirements to remain in accordance with corporate regulations.

by CA V. Viswanathan
FCA, ACS, CFE, Registered Valuer (S&FA) | Since 2012

Significant Beneficial Owner (SBO) Checker

Identify Significant Beneficial Owners under Section 90 of the Companies Act, 2013. Add each shareholder's details to check who qualifies as an SBO and understand BEN-1/BEN-2 filing requirements.

Shareholder #1

Frequently Asked Questions (FAQs)

1. What is the purpose of the SBO Compliance Checker?

The SBO Compliance Checker is designed to help users identify Significant Beneficial Owners in accordance with Section 90 of the Companies Act, 2013. It allows for the input of individual shareholder details to determine their status and clarify the specific filing requirements for BEN-1 and BEN-2.

2. How do I check if a shareholder is an SBO?

You can identify if a shareholder qualifies as a Significant Beneficial Owner by using the SBO Compliance Checker tool. Simply add each shareholder's specific details into the checker, which will then process the information to determine if they meet the criteria for SBO classification under the Companies Act.

3. Which forms are required for SBO compliance?

According to the article, understanding the filing requirements for BEN-1 and BEN-2 forms is a key feature of the SBO Compliance Checker. These forms are associated with the compliance process for Significant Beneficial Owners as defined under Section 90 of the Companies Act, 2013.

4. Does the SBO Checker support multiple shareholders?

Yes, the SBO Compliance Checker is designed to process shareholder data individually. Users are instructed to add each shareholder's details to the system to check whether they qualify as a Significant Beneficial Owner and to understand the corresponding filing requirements for BEN-1 and BEN-2 forms.

5. Is the SBO Compliance Checker based on the Companies Act?

Yes, the SBO Compliance Checker is based on Section 90 of the Companies Act, 2013. It is a tool maintained by CA V. Viswanathan that helps entities identify Significant Beneficial Owners and manage their related regulatory filing obligations such as BEN-1 and BEN-2.

Significant Beneficial Ownership (SBO) — Section 90 Framework

Section 90 of the Companies Act 2013 read with the SBO Rules 2018 (as amended) requires every reporting company to identify Significant Beneficial Owners — individuals who hold (directly or indirectly through layered structures) at least 10% of the company's shares, voting rights, distribution rights, or who exercise significant influence/control.

Compliance steps: (a) Identification of SBOs by the reporting company through reasonable steps including BEN-4 enquiry letters to members; (b) BEN-1 declaration submitted by each SBO; (c) BEN-2 filing by the company with ROC within 30 days of receipt of BEN-1; (d) BEN-3 register maintenance; (e) annual review embedded in the MGT-7 annual return process.

Penalties: ₹10 lakh on company, daily continuing penalty up to ₹50 lakh, ₹2 lakh on every officer in default. Most importantly — BEN-3 freezing of shares of unidentified SBOs.

This checker helps determine whether an individual qualifies as SBO and the documentation required. For multi-layer ownership structures (foreign holdcos, trusts, LP-LP chains), consult CA V. Viswanathan at +91 99622 60333.

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