When planning to register a company in India, many entrepreneurs assume that obtaining a Digital Signature Certificate (DSC) is the very first and mandatory step. While that’s partially true for most full incorporations, recent changes in the MCA (Ministry of Corporate Affairs) portal and the introduction of SPICe+ forms have simplified the process.
In some cases, it is now possible to initiate or even complete company registration without obtaining a DSC upfront—depending on how you’re submitting documents and what stage you’re at.
Let’s understand why and how a company can be registered without DSC registration, what the exceptions are, and when you still need one.
💡 What is DSC and Why It’s Usually Needed?
A Digital Signature Certificate (DSC) is an electronic form of a physical signature. It is used to securely sign online documents, particularly while interacting with government portals like:
MCA (for company registration)
Income Tax Department (for filings)
DGFT (for export/import)
EPFO, GST, etc.
Traditionally, DSC registrations is required to sign incorporation documents like MOA, AOA, and forms like SPICe+, AGILE, and INC-9.
✅ Why Company Registration Can Be Done Without DSC (Initially)
With the MCA SPICe+ system (Simplified Proforma for Incorporating Company Electronically), a few key steps can be completed without a DSC, especially:
1. Name Reservation
You can file Part A of SPICe+ (which reserves the name of your company) without a DSC. This helps you start the registration process even before purchasing digital signatures.
2. Offline Form Preparation
All forms like SPICe+ Part B, AGILE-PRO, INC-9 can be filled online on the MCA portal. In certain cases (especially for companies with only one director and subscriber), MCA auto-generates INC-9 with E-verification, thus eliminating the need for a DSC.
3. Using PAN-Based E-sign
If the director/shareholder already has their PAN linked with Aadhaar, they can use Aadhaar-based e-sign in some limited contexts—like LLP filings or GST application. However, for company incorporation, MCA still prefers DSC for final submission.
🔍 When DSC is Still Required
Even though you can start the registration process without DSC, it is still required at the final submission stage in these scenarios:
When there are multiple directors/subscribers
For signing MoA & AoA digitally
For SPICe+ final submission
For filing DIR-3 (DIN) if not using SPICe+ auto-DIN
For post-incorporation filings (e.g., PAS-3, INC-20A)
So while you can start without a DSC, you’ll eventually need it to complete the process.
⚙️ Benefits of Starting Without DSC
Faster name reservation
Saves initial cost if you’re unsure about proceeding
Useful for agents and professionals managing multiple registrations
Allows businesses to prepare documents while DSC is being applied
📌 Practical Tip
If you're registering through a CA, CS, or professional service, they can often prepare and preview all required forms for you using their own DSC, and you can sign the final version once your DSC is ready.
✍️ Conclusion
While DSC is a mandatory component for full company incorporation in India, the initial steps of company registration can now be done without it—thanks to improvements in the MCA filing system. This flexibility helps speed up the process and reduce upfront cost barriers for entrepreneurs.
