Register of directors and key managerial personnel

Section 170 requires a register of directors and key managerial personnel, including the securities each of them holds in the company and its group. Rule 17 lists what it must contain.

What goes in it

• Name, DIN (for directors) and particulars
• Date of appointment, reappointment and cessation, with reasons
• Other directorships
• Securities held in the company, its holding, subsidiary and associate companies

Mistakes that come up

• A resignation recorded on the MCA portal but not in the register
• Shareholdings of directors not updated after an allotment

Keeping it electronically

Section 120 allows records to be kept in electronic form in the manner the rules prescribe. Rule 27(1) of the Companies (Management and Administration) Rules, 2014 speaks of listed companies and companies with 1,000 or more shareholders, debenture holders and other security holders; for a smaller company, whether Keel holds the register itself or a sealed copy kept beside it is for the company and its company secretary to decide. Rule 28 sets the conditions for electronic records, among them protection against unauthorised alteration, a dated backup at least once a day, records that can be reproduced in readable form, and systems that can "discern invalid and altered records" (rule 28(2)(e)); under it the board names who is responsible, where backups are kept and who has access.

How it is kept on Keel

Each entry is sealed with a fingerprint chained to the one before it, and a correction is a new entry that points at the one it corrects, so the register shows its own history. Your firm keeps preparing it in the tool it uses today; Keel imports the export. See a sealed register of members.