GST invoice format for a practising company secretary
A practising company secretary's invoice should list each corporate filing or engagement with the company name, CIN and the form or event: incorporation, annual filing (AOC-4, MGT-7), director changes, secretarial audit or a compliance retainer. These are professional services taxed at 18%, generally coded under SAC 998399 for other professional services, with documentation work under 998214. MCA filing fees and stamp duty paid in the client's name should be shown as pure-agent reimbursements outside the taxable value, with SRN references.
Download this format free
Pre-filled with company secretary sample items and fields. No sign-up.
Private limited company incorporation, documentation and SPICe+ filing
998399
1 OTH
15,000.00
15,000.00
18%
Annual filing for FY 2025-26: AOC-4 and MGT-7A
998399
1 OTH
12,000.00
12,000.00
18%
Secretarial audit and Form MR-3 report, FY 2025-26
998399
1 OTH
40,000.00
40,000.00
18%
Drafting of shareholders' agreement and board resolutions
998214
1 OTH
25,000.00
25,000.00
18%
Compliance retainer: minutes, registers and event-based filings, quarterly
998399
3 OTH
5,000.00
15,000.00
18%
Taxable value
₹1,07,000.00
GST (CGST + SGST, or IGST if inter-state)
₹19,260.00
Invoice total
₹1,26,260.00
Sample prices are illustrative. Check the GST rate for your exact item or service before billing.
Extra fields a company secretary invoice needs
ICSI membership and certificate of practice number
Certifications on MCA forms are valid only from a CS holding a certificate of practice. Printing the membership and COP numbers on the invoice ties the fee to the professional who signed the forms.
Client CIN
A practising CS handles many companies under one group. The Corporate Identification Number on each invoice prevents fees being booked to the wrong entity.
Form name and SRN
Each MCA filing generates a Service Request Number. Quoting the form and SRN proves the filing and lets the client track it on the MCA portal.
Financial year of annual filing
Annual returns and financial statements are filed for a specific year. Naming it avoids confusion when late filings for earlier years are billed together.
MCA and stamp duty paid
Government filing fees, additional fees for delay and stamp duty on incorporation are paid in the company's name. Show them separately as reimbursements with challan details.
Retainer period
Monthly or annual compliance retainers should state the period and the services included, such as board meeting minutes and statutory registers.
Standard GST invoice fields
Rule 46 of the CGST Rules applies to every tax invoice, including this one:
✓Supplier name, address and GSTIN
✓Consecutive invoice number (max 16 characters, unique for the year)
Company secretarial work is professional, technical and business service, which the services rate notification taxes at 18% under heading 9983 for services other than the specific entries. The official SAC list does not have a dedicated code for corporate secretarial practice, so most practitioners use 998399, other professional, technical and business services, and 998214 for legal documentation and certification concerning documents other than IP. Whichever you choose, use it consistently across invoices and returns so the HSN summary is stable year to year.
MCA fees as pure-agent costs
Filing fees on the MCA portal are paid in the company's name using its login and are a statutory levy. A CS who pays them on the client's behalf and recovers the exact amount meets the pure-agent conditions: the client is liable to pay the fee, the CS does not use the service, and the amount is shown separately. Keep the challan with the invoice. Additional fees for delays caused by the CS are a different matter commercially but are still the company's statutory liability.
Not under reverse charge
Reverse charge applies to services of advocates to business entities, not to company secretaries. A practising CS who is registered charges 18% forward on the invoice even when the client is a company. Confusing the two because both work on legal documents is a common error that leaves the tax unpaid.
Incorporation for startups
For new companies, the CS often bills before the company exists, with promoters paying personally. Raise the invoice in the company's name once it is incorporated and has a GSTIN if it wants credit, or in the promoter's name if the promoter paid and the company is not registered. Mention the CIN when it becomes available.
Retainers and event-based filings
Retainers cover routine compliance; events such as a share allotment, change in registered office or appointment of an auditor are often billed extra. Invoice extras when the filing is done, with the form and SRN on each line. This gives the client a clear audit trail for every filing paid for.
Registration and threshold
A CS practice with turnover up to ₹20 lakh (₹10 lakh in special category states) need not register. Corporate clients usually prefer a GST invoice to claim credit, which is why many smaller practices register voluntarily.
Common billing mistakes
✕Adding MCA filing fees into the taxable professional fee, so the client pays 18% on a statutory levy.
✕Treating company secretarial services as reverse charge like advocates' fees, leaving tax unpaid.
✕Billing a group's filings on one invoice to the holding company, so subsidiaries cannot claim their share of credit.
✕Omitting SRNs, which makes it hard for the client to match fees with filings on the MCA portal.
Company Secretary GST invoice: FAQ
What is the GST rate on company secretary services?
+
Professional services of a practising company secretary are taxed at 18% GST.
Which SAC code should a CS use?
+
Most practitioners use 998399 for secretarial compliance and 998214 for drafting legal documents. Both carry 18%.
Is reverse charge applicable on CS fees?
+
No. Reverse charge covers advocates' legal services, not company secretaries. A registered CS charges GST on the invoice.
Can I bill MCA fees without GST?
+
Yes, if you paid them in the client's name and recover them at actual cost as a pure agent, shown separately with the challan.
How should a group of companies be invoiced?
+
Raise a separate invoice for each company in the group, in its own name and with its own CIN and GSTIN, for the filings done for that company. A single invoice to the holding company for all subsidiaries leaves each subsidiary without a document to support its own input tax credit and its own expense, and auditors of the subsidiaries will ask for it.