DSC for Foreign Directors in India, Documents and Video KYC
How a foreign director gets a Class 3 DSC for Indian company filings: the CCA rules, the documents, the video check, personal or organisation certificates, renewal, and when a founder needs no DSC at incorporation.
Krystal7 Consultants · India entry, tax and compliance
Written by CA Nandini, Krystal7 Consultants. Last updated 26 October 2026.
A foreign director signs Indian company filings with a Class 3 Digital Signature Certificate (DSC). A certifying authority licensed by India's Controller of Certifying Authorities (CCA) issues it after online checks. The director uploads a passport, an address proof and a photo, verifies an email address and a mobile number, and records a live video. The CCA identity guidelines we checked on 26 Oct 2026 do not ask a foreign applicant for an apostille. Class 2 certificates stopped from 1 Jan 2021, so every new certificate is Class 3.
This page is for foreign founders and directors of an Indian company, and for the advisers who plan their filings. It covers the legal basis, the documents and the video check. It then covers personal and organisation certificates, the token, cost, where the DSC is used and renewal, with a worked example in rupees.
What is a digital signature certificate?
A digital signature is the electronic equivalent of a handwritten signature on an electronic record. Section 2(1)(p) of the Information Technology Act, 2000 (the IT Act) defines it. It is the authentication of an electronic record by a subscriber through an electronic method or procedure. Section 3 lets a subscriber authenticate a record by affixing a digital signature, which works through an asymmetric crypto system and a hash function.
The certificate is the electronic document that links a named person to a key pair. A certifying authority issues it under section 35 after it verifies the applicant. The CCA's FAQ states that digital signatures are at par with handwritten signatures under the IT Act.
The system has three layers. The central government appoints the Controller under section 17. The Controller licenses certifying authorities under section 21. The certifying authorities issue certificates to people and organisations, often through registration authorities that collect the documents.
Provision of the IT Act, 2000
What it does
Why a foreign director cares
Section 2(1)(p)
Defines a digital signature
The signature on SPICe+ and every MCA eForm is this kind of signature
Section 3
Lets a subscriber authenticate an electronic record with a digital signature
A signed eForm is an authenticated electronic record
Section 17
The central government appoints the Controller of Certifying Authorities
The CCA sets the identity rules every issuer follows
Section 21
The Controller licenses certifying authorities
Buy only from a licensed authority
Section 35
A certifying authority issues the certificate on an application
The application and the video check run through that authority
Section 38
A certifying authority revokes a certificate, including on the subscriber's request
This is the route when a token is lost
Section 42
The subscriber must keep control of the private key and report a compromise without delay
The token and its PIN are the director's responsibility
Sources: Information Technology Act, 2000 as enacted (MeitY copy) and CCA FAQ, both read 26 Oct 2026.
Why do MCA filings need a DSC?
The Ministry of Corporate Affairs (MCA) takes company filings online, and the forms carry digital signatures in place of ink. MCA's SPICe+ FAQs say the incorporation form is digitally signed by a director and by the certifying professional (FAQ 16). Signed forms are then uploaded with the linked forms (FAQ 15). Our SPICe+ guide covers the form itself.
Subscribers can sign the memorandum and articles electronically, as the eMoA (INC-33) and eAoA (INC-34). Where they do, each signer needs a DSC (FAQ 31). A foreign national can sign the eMoA and eAoA only with a valid DIN, a DSC and a valid business visa (FAQ 43). In practice, that means the foreign national signs while visiting India.
A foreign subscriber outside India signs a paper memorandum and articles instead. The signatures are attested in that country, and SPICe+ carries the attested copies as attachments (FAQ 44). Our guide to the memorandum and articles for a foreign subsidiary covers that drafting.
The director KYC also uses a DSC. From 31 Mar 2026, directors confirm KYC once every three years in place of every year, under G.S.R. 943(E) of 31 Dec 2025 (PIB, 1 Jan 2026). When the director uses the form to update a mobile number, email or residential address, the director verifies it with a digital signature. A professional then certifies it with their own.
Why is Class 3 the only class on offer?
Class 2 DSCs were discontinued from 1 Jan 2021. The Indian Patent Office's DSC page records this change under the CCA guidelines. The CCA Identity Verification Guidelines (CCA-IVG) now tell certifying authorities not to issue Class 2 individual signing certificates on their own.
A Class 3 certificate carries both the Class 2 and the Class 3 policy identifiers, so it counts as both. The CCA FAQ confirms that a Class 3 certificate can be used where an application asks for Class 2. Any certificate a director buys now, including a replacement, is Class 3.
Class
What the CCA documents say
Key storage
Class 1
A subscriber may choose a software key once the risks are disclosed and the subscriber signs an undertaking
Software or hardware module
Class 2
Not issued alone for individual signing; discontinued from 1 Jan 2021
Hardware token validated to FIPS 140-2 level 2
Class 3
Issued for personal and organisational signing; carries the Class 2 and Class 3 identifiers
Key generated on a module validated to FIPS 140-2 level 2 or 3
Sources: CCA-IVG section 1.13 and CCA FAQ, read 26 Oct 2026; IP India, Digital Signatures (USB DSC token) page, read 26 Oct 2026.
Who issues DSCs in India?
Only certifying authorities licensed by the CCA issue DSCs. The CCA itself issues certificates only to certifying authorities, not to end users. On 26 Oct 2026, the CCA's licensed CA page listed 24 authorities, including the Indian Army, Navy and Air Force. The CCA's page on getting a DSC lists 14 licensed authorities that issue certificates to the public.
Each authority sets its own price, and the CCA FAQ says the price may vary from CA to CA. The identity standard is the same for all of them, because every authority must follow the CCA-IVG. The CCA home page also carries an advisory to application owners on mandatory acceptance of valid DSCs issued by any licensed CA.
We do not recommend a particular issuer. Check the licensed list on cca.gov.in before anyone takes payment. Registration authorities collect documents and help applicants, but the certificate itself must come from a licensed authority.
Which documents does a foreign national need for a DSC?
Section 2.6 of the CCA-IVG covers foreign applicants. An applicant is foreign when the application address is outside India. An applicant is also foreign when no Indian government authority issued the identity document. Every applicant submits an email address, a mobile number, a photo, and scanned proofs of identity and address.
Item
What the CCA-IVG accepts for a personal certificate
Our note
Identity proof
Passport, local government ID, PAN or OCI passport
Use the passport, so the name matches the DIN and SPICe+
Address proof
Passport, OCI passport, local government ID with address, bank details with address, a utility bill issued within three months, or an embassy document with a residential address
Pick a document with the same address you will give MCA
Photo
A photo with the application
A recent photo on a plain background
Email
Verified by the certifying authority
A personal address the director checks daily
Mobile number
Verified by an SMS OTP or a direct call
The guidelines we checked do not ask for an Indian number
Video
Live video under Annexure VI, with originals shown
See the video section below
Source: CCA-IVG section 2.6 and Annexure VI, read 26 Oct 2026.
The certifying authority activates the eKYC account after the mobile, email and video checks, plus PAN where one is given. The applicant also signs a subscriber agreement digitally. A change to the account details after activation needs fresh enrolment. An OCI holder can use the OCI passport as both identity proof and address proof.
MCA applies its own identity rules. Rule 16 of the Companies (Incorporation) Rules, 2014 asks a foreign national subscriber for a passport. It also limits a bank statement, electricity bill or telephone bill used as residence proof to two months old. The CCA-IVG accepts a utility bill up to three months old. One document under two months old satisfies both.
Does a foreign director's DSC need an apostille?
Not under the CCA-IVG we checked on 26 Oct 2026. Section 2.6 relies on scanned documents, a video check with the originals, and mobile and email verification. It does not mention apostille, notarisation or consular attestation.
Older versions did. Version 1.9 of the guidelines was released on 5 Sep 2019 and last updated on 28 Apr 2020. It asked a foreign applicant in a Hague Convention country to have documents notarised and apostilled. In other countries, it asked for notarisation and consularisation.
In our experience with Commonwealth founders, DSC issuers have issued the DSC on the notarised copy. Ask the certifying authority for its document list before the director books a notary.
Point
CCA-IVG version 1.9 (2019 and 2020)
CCA-IVG as checked on 26 Oct 2026
Attestation of foreign documents
Notarised and apostilled, or notarised and consularised
Not mentioned
Verification route
Attested documents plus video
eKYC account with video, mobile and email checks
Mobile check for a foreign applicant
Exempted
Required, by SMS OTP or a direct call
Video for each certificate
Fresh video within 2 days of each issue on the eKYC route
Fresh video within 2 days of each issue
Sources: CCA-IVG version 1.9 (copy hosted on cdasecbad.ap.nic.in) and CCA-IVG on cca.gov.in, both read 26 Oct 2026.
How does the DSC video verification work?
Annexure VI of the CCA-IVG sets the video rules. The certifying authority runs the session inside its own application, and it records one way only. It does not accept an offline recording or an uploaded file.
Open the video link from the certifying authority's application on a laptop or phone with a camera.
State your name and your intention to apply for a DSC through that certifying authority.
Read aloud the random code on the screen. It has at least three digits, and each session generates a new code.
Show the original passport and address proof. Hold each by the edges without covering the text, or lay it flat.
Keep the session going for at least 20 seconds.
The face must be fully visible and fill about half the frame, in bright light without dark shadows. Caps, headgear, eyeglasses, headphones and sunglasses are not allowed. A plain background is preferred.
Timing matters across time zones. The video must fall within the last 2 days before each certificate is issued. The applicant then has 30 days from approval to download the DSC, or the authority repeats the checks. The eKYC account itself lasts no more than 2 years, and only fresh verification extends it.
Should a director take a personal or an organisation DSC?
A personal certificate names the individual alone. An organisation certificate names the individual as a person acting for a named organisation. Both are Class 3, and both keep the key on validated hardware.
The CCA FAQ says a person may hold more than one DSC, including from different authorities. It also says the DSC must be revoked when a subscriber leaves an organisation. A director may sit on several boards over time, so a certificate tied to one employer is a poor fit for MCA work.
Point
Personal certificate
Organisation certificate
Who it names
The individual
The individual and the organisation
Extra documents for a foreign applicant
None beyond identity, address, photo, email and mobile
Organisation ID, organisational email and address, an authorisation letter, and publicly verifiable proof that the organisation exists in a local government registry
When the person leaves the organisation
Not affected
The CCA FAQ says to revoke the certificate
Fit for a foreign director of an Indian company
Good, because it stays with the person
Only if the employer must appear on the certificate
Sources: CCA-IVG sections 2.3 and 2.6, and CCA FAQ, read 26 Oct 2026.
An organisation certificate for the new Indian company is not possible before incorporation. The CCA-IVG asks for proof that the organisation exists, and the company does not exist until the certificate of incorporation issues.
How long is a DSC valid, and what is the USB token?
The certifying authority offers the validity options at purchase, and each certificate states its own start and end dates. The CCA documents we read for this page do not fix one term for all certificates. Diary the end date when the certificate arrives.
A signature stays valid after the certificate expires. The CCA FAQ explains that a signature is checked against the time it was affixed. A form signed while the certificate was valid stays valid.
The token is a small USB crypto device. For Class 3, the signing key is generated on a module validated to FIPS 140-2 level 2. The CCA FAQ says the signing key cannot be copied off the device. Each certifying authority must publish its list of approved token makers on its website.
Section 42 of the IT Act makes the subscriber responsible for control of the private key. Keep the token and the PIN with the director. If the director lives abroad, plan who signs which form, so the token never has to sit with someone else.
What does a DSC cost for a foreign national?
The CCA does not publish a single price. Its FAQ says the price may vary from CA to CA. The price for a foreign director depends on these points:
The validity period chosen.
Whether the director needs a new token or already holds a compatible one.
Whether the certificate is personal or organisational, because the organisation checks add work.
Courier of the token, where the director lives abroad.
Any notarised copies the certifying authority asks for.
A DSC is not a government fee, so it does not appear on the MCA challan. Our published fee band for an India subsidiary of a foreign parent is USD 1,200 to USD 1,700 (Krystal7 pricing page, Oct 2026). The band includes DSCs for the foreign signatories. Government fees are passed on at cost, with no markup, as separate lines.
Where is the DSC used after it is issued?
The table lists the filings where we see a foreign director's DSC in use, with the source for each.
Filing
Who signs with a DSC
Source
SPICe+ (INC-32) and linked forms
A director and the certifying professional
MCA SPICe+ FAQs 15 and 16
eMoA (INC-33) and eAoA (INC-34)
Each subscriber who signs electronically; a foreign national also needs a DIN and a valid business visa
MCA SPICe+ FAQs 31 and 43
Director KYC under rule 12A (DIR-3 KYC), once every three years from 31 Mar 2026
The director, when updating mobile, email or address, with a professional's certification
PIB release, 1 Jan 2026
One Person Company incorporation
The nominee needs a DSC
Krystal7 filings
Sources: MCA, FAQs on Incorporation and Allied Matters; PIB, 1 Jan 2026; read 26 Oct 2026.
Not every foreign founder needs a DSC to incorporate. The answer depends on where and how each person signs. The table sets out the cases we file most often.
Founder setup
Who needs a DSC at incorporation
Basis
Foreign founder signs abroad on the apostille route
Only the Indian director; the foreign founder signs the paper memorandum and articles physically
Krystal7 filings; MCA SPICe+ FAQ 44
Commonwealth founder signs before a local notary
The founder signs on paper; if the founder takes a DSC, issuers have issued it on the notarised copy
Krystal7 filings; rule 13(5); MCA SPICe+ FAQ 28
Foreign national signs in India on a valid business visa and holds a DIN
The foreign national can sign the eMoA and eAoA with a DSC
MCA SPICe+ FAQ 43
One Person Company
The nominee needs a DSC
Krystal7 filings
Any incorporation
The certifying professional signs SPICe+ with their own DSC
MCA SPICe+ FAQ 16
Sources: Krystal7 filing records; MCA, FAQs on Incorporation and Allied Matters, read 26 Oct 2026.
On the apostille route, the Indian director signs SPICe+. Our resident director guide explains the residency test that director must meet.
A UK company sets up a wholly owned subsidiary in Gurugram, Haryana. We assume:
Authorised capital of ₹15 lakh.
Two subscribers: the UK parent and a UK national director who holds one share as its nominee.
Two directors: the UK national, who signs in London, and an Indian resident director in Gurugram.
The UK director signs the paper memorandum and articles before a UK notary, and the parent's authorised signatory signs for the parent the same way.
The DSC plan follows from where each person signs.
Person
DSC at incorporation?
Why
Indian resident director
Yes, a Class 3 personal certificate
Signs SPICe+ and the linked forms as director
UK national director
No
Signs the paper memorandum and articles before a UK notary
UK parent's authorised signatory
No
Signs the parent's documents on paper
Certifying professional
Yes, their own
Certifies SPICe+
Sources: MCA SPICe+ FAQs 16, 28 and 44, read 26 Oct 2026; Krystal7 filing experience with Commonwealth founders.
The government fees come from a real SPICe+ challan we paid for a Haryana company with ₹15 lakh authorised capital on 14 Aug 2026.
Item
Amount
Name reservation
₹1,000
MCA registration fee for authorised capital up to ₹15 lakh
Nil
Fee for SPICE + Part B (₹143 for PAN and TAN)
₹143
Stamp duty on the memorandum
₹60
Stamp duty on the articles
₹120
Stamp duty on linked forms
₹15
Total government fees
₹1,338
Sources: Krystal7 SPICe+ challan, Haryana, paid 14 Aug 2026; Companies (Registration Offices and Fees) Rules, 2014 (registration fee nil up to ₹15 lakh from 18 Mar 2019).
The DSC for the Indian director is not on this challan. The certifying authority quotes it, and our fee band covers it. Our company registration cost calculator runs the same arithmetic for other states and capital amounts.
The timeline on our filings runs like this. Name reservation takes 48 working hours. Drafting takes 36 working hours after the documents arrive. Notarisation takes the UK director about 4 to 5 business days. We file within 24 working hours of receiving the attested documents, and approval takes a further 96 to 120 hours.
Later, the UK director wants a DSC for KYC updates and later MCA forms. The director completes the video check within 2 days of issue and downloads the certificate within 30 days of approval. On our filings with Commonwealth founders, issuers have accepted the notarised passport copy from the incorporation pack.
How do you renew a DSC or replace a lost token?
Renewal works as a fresh issue. The eKYC account lasts no more than 2 years, and each new certificate needs a fresh video within the 2 days before issue. Start about a month before the end date, so the old and new certificates overlap.
After the new certificate arrives, register it on each portal where the old one was registered. Do this before the next filing, not on the deadline day. The CCA FAQ allows a person to hold more than one DSC, so an overlap causes no conflict.
A lost or compromised token is more urgent. Section 42(2) of the IT Act requires the subscriber to tell the certifying authority without delay. Section 38(1) lets the authority revoke the certificate at the subscriber's request. Then apply for a new certificate with fresh verification.
Forms signed before the loss stay valid, because a signature is checked against the time it was affixed. Tell the company's compliance team the same day, so nobody tries to sign with the revoked certificate.
Common mistakes
Asking for a Class 2 certificate. Fix: Class 2 is not issued alone since 1 Jan 2021. Ask for a Class 3 personal certificate.
Apostilling the passport for a DSC by default. Fix: the CCA-IVG we checked does not ask for it. Ask the certifying authority for its list, and use a notarised copy where one is already being made.
Mismatched names. Fix: apply in the full passport name, so the DSC, the DIN record and SPICe+ carry one spelling.
Using a three month old bill for MCA. Fix: the CCA accepts three months, but rule 16 limits MCA residence proof to two months. Use one document under two months old.
Leaving the token and PIN with the Indian team. Fix: section 42 puts control of the key on the director. Plan the signing order so the director signs.
Missing the 30 day download window. Fix: download the certificate the day it is approved, or the checks start again.
Recording the video in glasses or poor light. Fix: remove glasses and headphones and face the light. Keep the face at about half the frame.
Taking an organisation certificate tied to the parent company. Fix: use a personal certificate. An organisation certificate must be revoked when the person leaves.
Buying a DSC for a founder who signs on paper. Fix: on the apostille route, the foreign founder signs physically. Only the Indian director needs a DSC at incorporation.
Forgetting the OPC nominee. Fix: an OPC nominee needs a DSC, so start that application with the incorporation pack.
Checklist for a foreign director's DSC
Decide who signs electronically and who signs on paper at incorporation.
Confirm the certifying authority on the CCA's licensed CA list.
Choose a Class 3 personal certificate.
Scan the passport and an address proof under two months old.
Apply in the full passport name.
Verify the email address and the mobile number when the codes arrive.
Book the video for a time when the director has the original documents.
Complete the video and the subscriber agreement.
Download the certificate within 30 days of approval.
Keep the token and PIN with the director.
Register the certificate on each portal where the director will sign.
Diary the end date and start renewal about a month before it.
If the token is lost, ask the certifying authority to revoke the certificate the same day.
Yes. The CCA FAQ answers this question with a yes, and section 2.6 of the CCA-IVG sets the procedure for foreign applicants. The applicant submits a passport, an address proof, a photo, an email address and a mobile number, then completes a live video check.
Is a Class 2 DSC still available?+
No. Class 2 certificates were discontinued from 1 Jan 2021, as the IP India DSC page records. The CCA-IVG now bars certifying authorities from issuing Class 2 individual signing certificates on their own, and a Class 3 certificate counts as both classes.
Does a foreign director need an apostilled passport for a DSC?+
Not under the CCA-IVG we checked on 26 Oct 2026. Section 2.6 uses scanned documents and a video check, and it does not mention apostille. In our experience with Commonwealth founders, DSC issuers have issued the DSC on a notarised copy.
Does a foreign director need an Indian mobile number?+
The CCA-IVG we checked does not ask for one. It requires a mobile number that the certifying authority verifies by SMS OTP or a direct call. Check with the certifying authority before applying, because its system has to reach the number.
Does every foreign founder need a DSC to incorporate?+
No. On the apostille route, the foreign founder signs the memorandum and articles physically, and only the Indian director needs a DSC. A foreign national can sign the eMoA and eAoA electronically only with a DIN, a DSC and a valid business visa, under MCA SPICe+ FAQ 43.
Can an OCI holder use the OCI passport for a DSC?+
Yes. Section 2.6 of the CCA-IVG lists the OCI passport as both identity proof and address proof. Use the same name on the DIN and on MCA forms.
How long does the DSC video take?+
At least 20 seconds, under Annexure VI of the CCA-IVG. The applicant states the intention to apply, reads a random code of at least three digits, and shows the original documents. A fresh video is needed within the last 2 days before each certificate is issued.
What happens to signed filings when a DSC expires?+
They stay valid. The CCA FAQ explains that a signature is checked against the time it was affixed. A form signed while the certificate was valid keeps its signature after expiry.
Can one person hold two DSCs?+
Yes. The CCA FAQ says a person may hold more than one DSC, including certificates from different authorities. This is useful during renewal, when the old and new certificates overlap.
Who should keep the USB token?+
The director. Section 42 of the IT Act requires the subscriber to exercise reasonable care to retain control of the private key. Plan the signing order so that the token never has to leave the director.
How much does a DSC cost for a foreign national?+
The CCA does not fix a price, and its FAQ says the price may vary from CA to CA. The validity period, the token, courier abroad and organisation checks all move the price. Our India subsidiary setup fee band of USD 1,200 to USD 1,700 includes DSCs for the foreign signatories.
What should a director do if the DSC token is lost?+
Tell the certifying authority without delay, as section 42(2) of the IT Act requires. The authority can revoke the certificate at the subscriber's request under section 38(1). Then apply for a new certificate with a fresh video check.
Can the new Indian company get an organisation DSC before incorporation?+
No. The CCA-IVG asks for proof that the organisation exists, and the company exists only from its certificate of incorporation. Plan personal certificates for the directors who sign SPICe+.
Does a foreign director need a DSC for KYC?+
Often, yes. From 31 Mar 2026, director KYC is once every three years under G.S.R. 943(E) of 31 Dec 2025. When the director updates a mobile number, email or address through the form, the director verifies it with a digital signature.
Sources
Ministry of Electronics and Information Technology, Information Technology Act, 2000 (as enacted), read 26 Oct 2026, https://www.meity.gov.in/static/uploads/2024/03/ITbill_2000.pdf
Controller of Certifying Authorities, Identity Verification Guidelines (CCA-IVG), read 26 Oct 2026, https://cca.gov.in/sites/files/pdf/guidelines/CCA-IVG.pdf
Controller of Certifying Authorities, Identity Verification Guidelines version 1.9 (5 Sep 2019, updated 28 Apr 2020), copy hosted on cdasecbad.ap.nic.in, read 26 Oct 2026, https://cdasecbad.ap.nic.in/circulars/CCA-IVG.pdf
Controller of Certifying Authorities, PKI guidelines page, read 26 Oct 2026, https://www.cca.gov.in/guidelines.html
Controller of Certifying Authorities, FAQ, read 26 Oct 2026, https://cca.gov.in/faq.html
Controller of Certifying Authorities, Licensed CAs, read 26 Oct 2026, https://cca.gov.in/licensed_ca.html
Controller of Certifying Authorities, How to get Digital Signature Certificate, read 26 Oct 2026, https://cca.gov.in/digital_signature.html
Controller of Certifying Authorities, home page notices, including the advisory on mandatory acceptance of valid DSCs, read 26 Oct 2026, https://cca.gov.in
Office of the Controller General of Patents, Designs and Trade Marks, Digital Signatures (USB DSC token) information, read 26 Oct 2026, https://ipronline.ipindia.gov.in/epatentfiling/Extras/Digital_Signatures_Information.aspx
Ministry of Corporate Affairs, FAQs on Incorporation and Allied Matters (SPICe+), read 26 Oct 2026, https://www.mca.gov.in/Ministry/pdf/SpicePlusFAQS_20112020.pdf
Ministry of Corporate Affairs, Companies (Incorporation) Rules, 2014, G.S.R. 250(E), 31 Mar 2014, read 26 Oct 2026, https://www.mca.gov.in/Ministry/pdf/NCARules_Chapter2.pdf
Press Information Bureau, MCA replaces Annual KYC requirements under the Companies Act, 2013 with abridged KYC requirements once in three years, 1 Jan 2026, read 26 Oct 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2210552®=3&lang=1
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Nandini Hasija is a co-founder of Krystal7. She leads brand, business development and marketing, and works with founders to define their engagement. She is a Chartered Accountant and achieved All India Rank 49 in the CA examinations.
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