# Verification record — `in/mca/company-incorporation-spice-plus` v1.0.0 This file is the source-review record for this document version, per the [`manual-source-review-v1`](../../../../../practices/manual-source-review-v1.md) practice. ## Current claim - **`status`:** `draft` - **`verification.method`:** `manual-source-review-v1` - **`verification.lastVerifiedAt`:** `2026-07-03` `draft`, not `verified`, because no live walkthrough of the MCA21 portal wizard was performed — see "What was not done" below. This schema is sourced from the MCA's own downloadable instruction kits plus a very recent Wayback Machine capture of the live Adaptive Form HTML itself. ## Sources examined - **Document `(id, version)`:** `in/mca/company-incorporation-spice-plus` / `1.0.0` - **Spec version:** GovSchema `0.3.0` - **Authority:** Ministry of Corporate Affairs, Government of India (MCA21 portal), under the *Companies Act, 2013* and the *Companies (Incorporation) Rules, 2014*. - **Direct access attempts to `mca.gov.in` all failed with HTTP 403** (`curl`, `WebFetch`, and a headless Playwright pass with a realistic desktop user agent all returned Akamai's `Access Denied` edge page, `errors.edgesuite.net`). This is an IP/ASN-level WAF block, not a JavaScript bot-challenge — the same class of permanent block previously hit at `nzta.govt.nz` and `i-kfz.de` (see `gov474-dmv-business-formation- vertical-and-xfa-extraction` in prior-cycle notes) — so a real browser from this environment's egress does not defeat it. - **`https://web.archive.org/web/20230331084143/https://www.mca.gov.in/content/dam/mca-aem-forms/instructionkits/Instruction%20Kit_SPICe+Part%20A.pdf`** — "Instruction Kit for webform SPICe+ Part A (Name Reservation)" (11 pages). Retrieved via `curl` against the Wayback Machine mirror (HTTP 200, 499,364 bytes), text-extracted with a scratch npm install of `pdfjs-dist` (legacy build). Supplies the name-reservation field-level instructions (proposed name rules, NIC-code search, fee schedule) referenced by `proposedName1`/`proposedName2`/`nicCode1..3`. - **`https://web.archive.org/web/20230714092841/https://www.mca.gov.in/content/dam/mca-aem-forms/instructionkits/Instruction%20Kit_SPICe%20+%20Part%20B.pdf`** — "Instruction Kit for Form No. SPICe+ Part B" (19 pages). Retrieved and decoded the same way (HTTP 200, 439,593 bytes). Supplies the numbered field-level validation rules quoted in several `description`s (e.g. `entrenchmentArticleCount`'s 88-article cap for a Private OPC, the authorized/subscribed-capital comparison rule, OPC eligibility criteria under Rule 3, DIN-count caps). - **`https://web.archive.org/web/20260109225642/https://www.mca.gov.in/content/forms/af/mca-aem-forms/spice-part-b/spice-plus-part-b.html`** — a Wayback Machine snapshot of the **live SPICe+ Part B Adaptive Form HTML itself**, captured 2026-01-09 (six months before this review), retrieved via `curl` (HTTP 200, 5,730,099 bytes as served by `web.archive.org`). Unlike the two instruction kits (which only narrate "fields that require detailed instructions," per their own stated scope), this capture's rendered DOM text contains the **complete field-by-field structure** of the actual portal form: every section heading, numbered sub-section (1(a), 3A(i), 4A/4B/4C, 5, 6A/6B/6C, 7A/7B/7C/7D, 8A/8B, 9A/9B, 10, 11, 12, 13), every printed field label, every dropdown's enumerated options, and every mandatory-field asterisk. This is this document's **primary field-level source** — every field name, label, enum option, and `sourceRef` in this schema is drawn from this capture's text (a Python regex-stripped rendering of the archived HTML's visible DOM text, saved to a scratch file and read section-by-section; no client-side JSON/AEM guide metadata was present in the archived capture, only the server-rendered text nodes). - **Web search** confirmed OPC eligibility (Section 3, Companies Act 2013; Rule 3, Companies (Incorporation) Rules, 2014 — natural person, Indian citizen, resident in India, one nominee required) and the AGILE-PRO-S linked-form scope (GSTIN/EPFO/ESIC/PTEC-PTRC/Shops & Establishment/bank account) cited in this schema's top-level `description` and "Out of scope" section below — used only to state those rules in prose, not as a field-level source. ## What was not done — the one honest gap No live walkthrough of the MCA21 portal's SPICe+ wizard was performed. `mca.gov.in` returned HTTP 403 (Akamai WAF) for every access path attempted in this environment — direct `curl`, `WebFetch`, and a headless Playwright browser session with a realistic desktop Chrome user agent. This is consistent with prior-cycle findings for the same domain (GOV-887: "MCA21 (mca.gov.in) 403-blocks direct WebFetch/curl, the same class of block hit at nzta.govt.nz/i-kfz.de"). Because the block operates at the IP/ASN level rather than via a JavaScript challenge, a real browser did not change the outcome — this rules out the `ie/irishimmigration`-style bot-check-defeat technique for this particular source. A future review with different network egress, or MCA account credentials for an authenticated session, should drive the live wizard directly to confirm on-screen field ordering, client-side validation masks, and whether the OTP-verification steps noted in this schema's field descriptions (`companyMobileNumber`, `companyEmail`, and each person's mobile/email) match the modelled fields exactly. ## Test run performed Phase 4 of this cycle's research brief calls for a test run with valid mock data. Since the live wizard could not be reached, this was performed as a structural test: a scratch Node script (`/tmp/spice-test/mocktest.mjs`, not checked into the registry) implements the GSP-0013 condition grammar (`equals`/`in`/`all`/`any`/`not`) and resolves `visibleWhen`/`requiredWhen` against three independent mock OPC incorporations: 1. A retail-trading OPC with a single founder and nominee, e-stamp duty paid electronically through MCA21, and a Company Secretary as the certifying professional. 2. The same OPC but with an entrenched AOA (`entrenchmentArticleCount` gated field), manually-paid (non-electronic) stamp duty (four conditionally-required fields), and an Advocate as the certifying professional (exercising `professionalMembershipCategory`'s `requiredWhen` — not required for an Advocate). 3. The same OPC with `sourceOfIncome` set to `no_income` (so `businessProfessionCode` is correctly *not* required) and both optional second/third NIC codes and a second proposed name supplied. All three scenarios: (a) supply every field that is required given its resolved visibility, (b) pass each field's own `validation` (pattern/enum/min-max), and (c) contain no reference to a field name absent from `fields[]` across every `visibleWhen`, `requiredWhen`, `documents[]` `requiredWhen`, and `steps[].fields` entry. All three passed on the first run; no schema defect was found by this test. The schema also validates against both the zero-dependency structural checker (`tools/validate.mjs`) and the full JSON Schema draft 2020-12 meta-schema via ajv (`tools/validate-ajv.mjs`). ## Modelling decisions - **Scoped to a One Person Company (OPC), not a Private/Public/Producer/ Section 8/Nidhi company or a Part I LLP-to-company conversion.** SPICe+ is one generic web form spanning every Indian company type; modelling every branch in one document would require enumerating each type's distinct subscriber/capital/nomination rules. OPC is chosen as the closest Indian analogue to a single-founder LLC formation — the same scoping instinct `gb/companies-house/company-incorporation-in01` used picking "the common case where one person is the sole director, the sole initial shareholder/subscriber" for GB's IN01. An OPC's structural minimum (one individual subscriber-cum-director, one mandatory nominee, one share class) also keeps the subscriber/director particulars in §§6–7 to a single block (§7B) instead of the form's repeating non-individual/multiple- subscriber tables. - **`typeOfCompany` is not modelled as a field.** The live form's dropdown offers Private (OPC)/Private/Public/Producer/Part I Others/etc., but since this document's scope is fixed to OPC, the dropdown's other branches would never be exercised — same precedent as `gb/companies-house/company- incorporation-in01`, which likewise omits a "type of company" field because its scope is fixed to private-limited-by-shares. - **Founder modelled as "not having valid DIN" (§7B), not "having valid DIN" (§7A).** A first-time solo founder incorporating their first company does not yet hold a Director Identification Number — SPICe+ itself is how DIN gets allotted (Companies Act 2013 s.7 read with s.153/154). The "having DIN" branch (§7A) is the case of someone who already directs another company and is out of scope. - **`founderNationality`/`nomineeNationality` enums restricted to `["india"]`, and `founderCitizenOfIndia`/`founderResidentInIndia` fixed to `true` via `validation.enum: [true]`.** Rule 3, Companies (Incorporation) Rules, 2014 restricts OPC eligibility (as subscriber or nominee) to a natural person who is an Indian citizen resident in India. Rather than model these as free enums that could accept a value this document's scope can't otherwise support (a non-Indian OPC subscriber is not legally possible), the constraint is encoded directly in `validation`, following this registry's convention of using `enum: [true]`/`enum: []` to pin a field to its only legally-possible value for the documented scope (see also `hasShareCapital`, `addressIsRegisteredOffice`, and each person's `PresentAddressSameAsPermanent` below). - **`hasShareCapital`, `addressIsRegisteredOffice`, and each person's `PresentAddressSameAsPermanent` are real printed form fields, pinned to their common-case value (`true`) via `validation.enum: [true]`, rather than omitted.** Unlike `typeOfCompany` (a branch-selector this document's scope makes moot), these three are genuine yes/no questions every OPC filer answers, and the `false` branch in each case leads to real, additional on-screen fields (a company limited by guarantee's member-count table at §3B; a registered office distinct from the correspondence address; a present address distinct from the permanent one) that this version does not model. Pinning the field with `validation.enum: [true]` keeps the question itself faithful to the source form while making the scope boundary machine-checkable rather than only prose-documented. - **Preference share capital (§3A(ii)) not modelled.** Optional and rare for a newly-incorporated OPC (which typically issues only equity shares); omitted along with the "not having share capital"/§3B member-count branch. - **Entrenchment sub-table (Sr. No./Article number/description, under §1(b)) not modelled beyond the boolean gate and article count.** A rare edge case (custom AOA entrenchment clauses) whose repeating-row detail would add a disproportionate number of fields for a first version; the gating boolean and numeric cap are kept since they are simple, always- visible-on-the-form fields. - **Duration-of-stay-less-than-one-year → previous-residence-address branch (§7B(i), §8B) not modelled.** An edge case (a founder or nominee who moved within the last year); `DurationOfStayYears`/`Months` are collected, but the conditional previous-address sub-block is out of scope for this version. - **PAN/TAN jurisdiction codes (`panAreaCode`/`AoType`/`RangeCode`/`AoNumber` and their TAN counterparts) modelled as free-form strings, not enums.** These are official area/AO/range codes assigned by the Income Tax Department based on the registered office's jurisdiction (a large, address-dependent lookup table not published in either instruction kit or captured in the Adaptive Form snapshot), so no closed enum could be sourced faithfully; left as validated strings per this registry's practice of not inventing enum values the source does not publish. - **Multi-paragraph declaration blocks (§12 "Declaration", §13 "Declaration and Certification by Professional") each combined into one or two boolean fields** (`nameAndRegistrationDeclaration`, `directorDisqualificationDeclaration`), rather than one field per sentence, since each block is attached to a single digital signature on the live form — the same discipline used for `in/eci/voter-registration`'s `declarationAndConsent` and `nz/dia/passport-renewal-adult`'s combined declaration fields. - **OTP verification (mobile/email, throughout §§4A, 7B, 8B) not modelled as separate fields.** The OTP itself is a live-session runtime verification step performed against the value already collected in the mobile/email field, not a further piece of applicant-supplied data — documented in each affected field's `description` instead. - **`borderingCountryNationalSecurityClearance` retained even though this document's `founderNationality` is pinned to `india`.** This declaration is a printed, always-asked yes/no on the live form regardless of the signing director's own nationality (it exists to cover cases where a *different* proposed director is a bordering-country national), so it remains a real field; its `true` branch requires the `borderingCountrySecurityClearanceDocument` attachment (`documents[]`, `requiredWhen`). - **Comb/derived/system-computed amounts omitted.** `Total classified/ unclassified authorized share capital` (§3A) and the §9B(i) auto-computed stamp-duty-payable table are system-calculated from other collected values (number of shares × nominal value; authorized capital → fee schedule) rather than independently applicant-supplied, so — consistent with how this registry omits purely derived/prefilled fields elsewhere — they are not modelled; only the inputs that drive those computations are. - **AGILE-PRO-S, eMoA/eAoA, INC-9, and URC-1 linked web forms not modelled.** SPICe+ Part B's submission enables access to these as *separate* linked forms (GSTIN/EPFO/ESIC/PTEC-PTRC/Shops & Establishment registration and bank-account opening via AGILE-PRO-S; electronic MOA/AOA; declaration-in-lieu-of-affidavit via INC-9; Part I company conversion via URC-1) — each is its own webform with its own field set, out of scope for this version. Per Annexure A of the SPICe+ Part B instruction kit, e-MoA/ e-AoA is used automatically (not a manual attachment) whenever total subscribers ≤ 7, which is always true for an OPC's single subscriber, so `documents[]` omits a manual MOA/AOA attachment entry for this scope. ## Out of scope - **Private (non-OPC), Public, Producer, Section 8, and Nidhi companies**, and **Part I LLP-to-company conversions** — each has distinct subscriber- count minimums, capital-structure rules, and/or additional licensing fields (e.g. Section 8's license application) not modelled here. - **Non-individual (corporate) subscribers and multiple individual subscribers/directors** (SPICe+ Part B §§6A, 6B, 6C, 7A, 7C, 7D) — an OPC has exactly one subscriber-cum-director by definition, so this document models only §7B. - **Companies not having share capital** (§3B) and **preference share capital** (§3A(ii)). - **A registered office address distinct from the correspondence address**, and **a present address distinct from the permanent address** for the founder or nominee — both pinned to their common-case `true` value (see Modelling decisions). - **AGILE-PRO-S, eMoA/eAoA, INC-9, and URC-1 linked forms** (GSTIN, EPFO, ESIC, PTEC/PTRC, Shops & Establishment registration, bank account opening) — separate webforms with their own field sets; a natural candidate for a future GovSchema document once SPICe+ Part B itself is promoted past `draft`. - **Foreign Exchange Management Act (FEMA) non-debt-instruments declarations** (printed throughout §§6–7 for subscribers subscribing to shares) — not applicable given `founderNationality`/`nomineeNationality` are pinned to `india`. - **Resubmission flow** (a rejected/`Resubmission Required` SRN resubmitted with corrections) — this document models only the initial-submission data shape. ## Re-verification Per the practice's cadence, `nextReviewBy` is set to **2027-01-03** (6 months). Re-check whether `mca.gov.in` is reachable from a different network egress or via an authenticated MCA account session, and attempt a live walkthrough of the SPICe+ Part A + Part B wizard; if successful, promote `status` to `verified` and confirm the Adaptive Form snapshot used here has not since changed field structure.