Annual ROC Compliance Calendar 2026: What Every Indian Company Must File

Sep 1

25 min read

Authored by - Adv. Pranay Sawant, Senior Executive at Outsource360

Search for an ROC compliance calendar and you will get a table. Neat rows, fixed dates, one form per line. That table is the problem, because only a handful of the dates on it are actually fixed by statute. The rest are computed from an event your own board controls, and this year four separate rule changes moved the furniture while most of those tables stayed exactly where they were.

Start with the arithmetic nobody spells out. For a company with a 31 March year end, AOC-4 is not due on 30 October. It is due thirty days after your annual general meeting. Hold the AGM on 12 August and AOC-4 is due on 11 September, seven weeks before the date the calendar you downloaded told you. The 30 October figure is simply what happens if you use every day the law allows. It is a ceiling that has been widely reprinted as a deadline.

Now the four changes. On 1 December 2025, the small company thresholds in section 2(85) more than doubled, from Rs 4 crore of paid-up capital and Rs 40 crore of turnover to Rs 10 crore and Rs 100 crore. A whole tier of companies that filed the full MGT-7 last year files the abridged MGT-7A this year, holds two board meetings instead of four, and pays half penalties. Most calendars still print the old figures.

On 31 March 2026, director KYC stopped being an annual chore. The Ministry of Corporate Affairs replaced the yearly DIR-3 KYC with an intimation once every three years, and confirmed that directors already compliant are next due on 30 June 2028. Almost every published calendar still carries a DIR-3 KYC line against 30 September of this year. For most directors reading this, that line is wrong by two years.

On 30 June 2026, the old MCA21 V2 portal was switched off for good. Every Companies Act and LLP form now lives on V3, which asks for things V2 never did, including a photograph of the registered office carrying GPS coordinates that have to match the address on record.

And there is a clock running right now. The Companies Compliance Facilitation Scheme, 2026 lets a defaulting company clear its backlog of annual filings for ten percent of the accumulated additional fee, a ninety percent waiver. It was meant to close on 15 July, then 31 August. On 31 August 2026, the Ministry extended it once more, to 15 September 2026. If your company has unfiled AOC-4 or MGT-7 forms sitting behind it, you have until a fortnight from today to clear them cheaply, and the additional fee accrues at Rs 100 per day per form with no ceiling once that door shuts.

This guide is the calendar rebuilt from the sections rather than copied from the last calendar. It covers what a private limited company, an OPC and an LLP each file, when each date actually falls for FY 2025-26, what a missed date costs as it compounds, and the order to work in so the dates land on their own.

For a company with a 31 March year end, the ROC compliance calendar runs off one event: the annual general meeting, due by 30 September 2026 for FY 2025-26. AOC-4 follows within 30 days of that meeting, MGT-7 or MGT-7A within 60 days, and ADT-1 within 15 days of any auditor appointment. DPT-3, MSME-1 and DIR-3 KYC run on their own fixed dates, independent of the AGM.

That is the whole structure. What follows is each date, where it comes from, and the four places where the 2026 rules diverge from what most guides still say.

On this page

Why the ROC compliance calendar you found is probably wrong
Four things that moved before this filing season
The filings every company makes every year
The filings that depend on what the company actually did
The first year runs on a different calendar
LLPs file on a calendar of their own
What a missed ROC date actually costs
Working the calendar backwards so nothing slips
Frequently asked questions

Why the ROC compliance calendar you found is probably wrong

Registrar of Companies filings are not a list of anniversaries. They are a chain of consequences, and the first link is a meeting.

Almost every company date hangs off one event

Section 96 of the Companies Act, 2013 requires every company other than a one person company to hold an annual general meeting. Two limits apply at once, and the earlier of them wins: the meeting must happen within six months of the close of the financial year, and no more than fifteen months may pass between one AGM and the next.

For a 31 March 2026 year end, six months takes you to 30 September 2026, a Wednesday. That is the outer limit, not a target.

The first AGM is different, stricter in one way and looser in another. A newly incorporated company gets nine months from the close of its first financial year rather than six, but it gets no extension at all. For every subsequent AGM the company can apply to the Registrar in Form GNL-1 for up to three additional months, on special reasons. Ask early, because the Registrar is being asked to bless a delay, not to notice one after the fact.

Worth flagging: an AGM can be held on a Sunday. Section 96 bars only National Holidays, and requires the meeting to sit during business hours, between 9 am and 6 pm.

The FY 2025-26 dates, computed rather than copied

Below is what the calendar looks like if a company uses every day the statute allows and holds its AGM on 30 September 2026. Read the middle column, not the right one. The middle column is the rule; the right column is only one possible answer to it.

Filing or event	Statutory trigger	Date if the AGM is held 30 September 2026
Annual general meeting	Within 6 months of financial year close, section 96	Wednesday, 30 September 2026
ADT-1, auditor appointment	Within 15 days of the appointment, section 139	Thursday, 15 October 2026
AOC-4, financial statements	Within 30 days of the AGM, section 137	Friday, 30 October 2026
MGT-7 or MGT-7A, annual return	Within 60 days of the AGM, section 92	Sunday, 29 November 2026
OPC AOC-4	Within 180 days of financial year close, no AGM required	Sunday, 27 September 2026
OPC MGT-7A	60 days from the end of the 6-month AGM window	Sunday, 29 November 2026

Three of those six land on a Sunday. The V3 portal takes filings on a Sunday, but the professional certifying the form, the bank confirming a challan and the MCA helpdesk resolving a failed service request generally do not. Treat the Friday before as the real date and the weekend as the buffer you hope not to need.

Move the AGM and the whole calendar moves with it

Here is the part most guides skip. Bringing the AGM forward is the single cheapest compliance decision available to a small company, and it costs nothing.

Hold the meeting on 15 August 2026 instead of 30 September and AOC-4 falls due on 14 September, MGT-7A on 14 October. You have converted a November scramble into a September one, moved yourself out of the queue that forms in the last week of the window, and bought six clear weeks of slack before any additional fee can start running. The audit has to be finished either way. The only thing that changes is when you stop being exposed.

The mistake we see most often runs the other way. A company treats 30 September as the date, the auditor signs on 28 September, the board meets on 29 September, and one missing bank confirmation pushes everything past a statutory limit that has no grace period behind it.

Four things that moved before this filing season

Every one of these was notified or circulated between December 2025 and yesterday. Each changes what a company files, when, or what it costs.

The small company line jumped to Rs 10 crore and Rs 100 crore

The Companies (Specification of Definitions Details) Amendment Rules, 2025, notified as G.S.R. 880(E) on 1 December 2025, raised the small company thresholds in rule 2(1)(t), read with section 2(85). Paid-up share capital moved from Rs 4 crore to Rs 10 crore. Turnover, taken from the profit and loss account of the immediately preceding financial year, moved from Rs 40 crore to Rs 100 crore.

Both tests have to be satisfied, not one. And the status is not available at all to a public company, a holding or subsidiary company, a section 8 company, or a company governed by a special Act, however small it is. A wholly owned subsidiary with Rs 2 lakh of capital is not a small company. Plenty of founders discover this the first time their filing agent asks for MGT-7 rather than MGT-7A.

What the status buys is worth more than the shorter form:

The annual return goes on Form MGT-7A instead of MGT-7, with fewer disclosures, and it can be signed by a director alone rather than needing a company secretary.
Two board meetings a year satisfy section 173 instead of four, provided one falls in each half of the calendar year with at least ninety days between them.
No cash flow statement is required as part of the financial statements.
Auditor rotation under section 139(2) does not apply.
Penalties are halved under section 446B, capped at Rs 2 lakh for the company and Rs 1 lakh for an officer in default.

That last one is worth pausing on, because section 446B names three categories side by side: one person companies, small companies, and start-up companies. A start-up company for this purpose means a private company recognised under the notification issued by the Department for Promotion of Industry and Internal Trade. So DPIIT recognition, which most founders pursue for the section 80-IAC tax holiday, quietly halves penalty exposure on every Companies Act default as well. It is one of the few benefits of Startup India registration that costs nothing extra to claim and applies without a second application.

Status is tested year by year. Cross either threshold and the relief disappears the following year, which is a real consideration for a company that has just closed a round.

Director KYC stopped being annual

This is the change most likely to make your calendar wrong today.

Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014 used to require every DIN holder to file KYC each year by 30 September. The Companies (Appointment and Qualification of Directors) Amendment Rules, 2025, notified as G.S.R. 943(E) on 31 December 2025 and effective from 31 March 2026, replaced that with an intimation once every three years, due by 30 June. The old DIR-3 KYC e-form and the DIR-3 KYC Web version were merged into a single Form DIR-3 KYC Web.

The Ministry's own announcement of 1 January 2026 is unusually specific about who is affected, and it is the sentence to act on: "All directors who have completed their KYC till date are covered under the new provisions and accordingly their next KYC filing would be due by 30th June, 2028." Directors who had never filed were given until 31 March 2026 to reactivate their DINs under the old provisions.

So for the large majority of Indian directors, there is no KYC filing this year. Or next year. The next one is 30 June 2028, a Friday.

Two things still bite in the meantime. The same form is used to update a mobile number, an email address or a residential address, and a change has to be intimated within thirty days, independently of the three-year cycle. Verification by the director's digital signature and certification by a professional are required only where the form is being used for one of those updates. A DIN that has already been deactivated attracts a fee of Rs 5,000 to bring back.

One open question, and it is fair to say so rather than paper over it. The amended rule speaks of every individual holding a DIN as on 31 March of a financial year filing by 30 June of "the immediately following every third consecutive financial year". That reads cleanly for the existing population the Ministry has placed on a 2028 cycle. It is less obvious for a DIN allotted after 31 March 2026. If you took a DIN this year, confirm your first cycle with the professional who certified your incorporation rather than assuming 2028.

V2 is switched off, and V3 wants a photograph

Thirty-eight forms went live on the MCA V3 portal on 14 July 2025, covering annual filings, incorporation, charges, director KYC and event-based filings. The legacy MCA21 V2 portal was decommissioned permanently on 30 June 2026. There is no fallback route.

V3 is not V2 with a new skin, and the practical differences catch people out on the first filing of the season. The annual forms are web forms rather than downloadable PDFs, and they ask for the registered office address together with latitude and longitude, both as at the end of the financial year and as at the date of filing. A photograph of the registered office showing the external building and the company signboard is attached, in PDF or JPG, up to 2 MB, with GPS coordinates that match the address on record.

The submission mechanics changed too. Submitting generates a service request number, after which the DSC-affixed PDF is uploaded and the fee paid within defined windows, and missing either step cancels the request. MGT-7 in particular is processed straight through, with no resubmission facility, so an error is not something you correct on a second pass.

None of this is difficult. All of it takes longer than the fifteen minutes a founder who last filed on V2 has budgeted. Build in a fortnight of slack, not a weekend.

The 90 percent waiver window shuts on 15 September 2026

The Companies Compliance Facilitation Scheme, 2026 was introduced by MCA General Circular No. 01/2026 dated 24 February 2026. It lets a defaulting company file its pending annual returns and financial statements on payment of ten percent of the accumulated additional fee, a ninety percent waiver, under section 460 read with section 403.

The closing date has moved twice. The scheme was originally to run to 15 July 2026. General Circular No. 03/2026 dated 8 July 2026 extended it to 31 August 2026, citing capacity restoration at the MCA21 data centre after a fire there on 5 June 2026. Then General Circular No. 04/2026, dated 31 August 2026, extended it again, to Tuesday, 15 September 2026.

Two features make this materially different from the CFSS scheme of 2020. There is no separate immunity application to file: the V3 portal applies the reduced fee automatically when the relevant form is submitted. And the immunity from penalty is conditional rather than absolute. Broadly, filings made under the scheme are protected where they are completed before an adjudicating officer issues notice or within thirty days of such notice, while a company that files after that window has closed, or against which a penalty order has already been passed, stays liable.

If you are carrying a backlog, this is the fortnight. After 15 September the additional fee reverts to Rs 100 per day per form, running from the original due date, with no upper limit at all.

The filings every company makes every year

Four items, in the order they have to happen. Nothing here is optional, and nothing here depends on what the business did during the year.

The AGM, which is not a filing but sets every date

The meeting comes first because everything else is measured from it. Members receive at least twenty-one clear days' notice, the audited financial statements and the board's report are laid before the meeting, and the auditor is appointed or the existing appointment confirmed.

Shorter notice is possible with consent, but treat it as an exception rather than a plan. Those twenty-one days sit inside your window, not outside it, which is another reason the last week of September is the worst possible time to start.

AOC-4: the financial statements

Section 137 requires a copy of the financial statements, adopted at the AGM and including any consolidated statements, to be filed with the Registrar within thirty days of the meeting. The directors' report and the auditor's report ride along as attachments, which is why there is no separate ROC filing for the directors' report.

Variants exist, and picking the wrong one wastes a filing. AOC-4 XBRL applies to listed companies and their Indian subsidiaries, and to companies above prescribed capital or turnover limits. AOC-4 CFS covers consolidated statements where a company has subsidiaries. AOC-4 NBFC applies to non-banking financial companies reporting under Ind AS. Most private limited companies file plain AOC-4 and nothing else.

An OPC has no AGM, so section 137 gives it a fixed date instead: within 180 days of the close of the financial year, which is 27 September 2026 for FY 2025-26.

MGT-7 or MGT-7A: the annual return

Section 92 requires the annual return within sixty days of the AGM. It is a different document from the financial statements and it is not derived from them. It reports shareholding and any changes during the year, directors and key managerial personnel, meetings held, and remuneration.

Which form applies now turns on the December 2025 thresholds. One person companies and small companies file the abridged MGT-7A; everyone else files MGT-7. A certificate in Form MGT-8 from a practising company secretary goes with MGT-7 for listed companies and for companies above prescribed capital or turnover limits, and on V3 those fields sit inside the web form rather than arriving as a separate attachment.

Where an AGM was not held at all, the sixty days run from the last date on which it should have been held. Skipping the meeting does not stop the clock. It removes the event you would otherwise measure from, and leaves the default in place.

ADT-1: the auditor

Form ADT-1 intimates the Registrar of an auditor's appointment, within fifteen days of that appointment. In the ordinary annual cycle that means fifteen days after the AGM at which the auditor was appointed or reappointed.

The first auditor is a different animal, and belongs to the first-year calendar further down rather than this one.

The board paperwork that never reaches the Registrar

Some of the annual obligation produces no filing at all, which is exactly why it gets forgotten until an audit or a due diligence asks for it.

Section 173 requires four board meetings a year with no more than 120 days between consecutive meetings, reduced to one meeting in each half of the calendar year, at least ninety days apart, for a one person company, small company or dormant company. Statutory registers under section 88, including the register of members and the register of directors, are maintained and kept current. The board's report under section 134 is prepared and approved before the AGM.

None of this is filed on its own. All of it is the evidence base for what is filed, and for what a buyer's counsel will ask to see the day you raise or sell.

Form	What it reports	Due
ADT-1	Appointment or reappointment of the statutory auditor	15 days from the appointment
AOC-4 (or XBRL / CFS / NBFC variant)	Audited financial statements, directors' report, auditor's report	30 days from the AGM; 180 days from year end for an OPC
MGT-7	Annual return, companies other than OPCs and small companies	60 days from the AGM
MGT-7A	Abridged annual return, OPCs and small companies	60 days from the AGM, or from the date it should have been held

The filings that depend on what the company actually did

These are the ones a template calendar handles badly, because whether they apply to you is a question about your books rather than your form of incorporation.

DPT-3, which catches director loans

Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014 requires an annual return of deposits and of money received that is not treated as a deposit, filed by 30 June for the year ended 31 March.

The trap is the second half of that sentence. A private company that has taken an unsecured loan from a director, or money from a shareholder, or an inter-corporate loan, is reporting exempted receipts rather than deposits, and still has to file. Founders who have put their own money in, which is most founders, are usually in scope and frequently have no idea.

For FY 2025-26 the date moved. MCA General Circular No. 02/2026 dated 19 June 2026 extended DPT-3 from 30 June 2026 to 31 July 2026 without additional fee, again because of the June data centre fire. That extension is spent. Next year, plan for 30 June.

MSME-1, the one triggered by paying late

MSME Form 1 is a half-yearly return of outstanding payments to suppliers registered as micro or small enterprises, due by 30 April for the October to March half and by 31 October for the April to September half.

It is triggered by conduct, not by size. If any payment to an MSME supplier remains outstanding beyond forty-five days from acceptance or deemed acceptance, the return is due. Pay everyone inside forty-five days and there is nothing to report. Which is rather the point of the rule.

31 October 2026 is a Saturday. Put it in the same week as the AOC-4 work and file both together.

DIR-3 KYC, now once every three years

Covered in full above. For directors already KYC compliant, the next filing is 30 June 2028. For anyone updating a mobile number, an email address or a residential address, the same form is due within thirty days of the change. A deactivated DIN costs Rs 5,000 to reactivate.

BEN-2, PAS-6, CSR-2 and the event-driven rest

The remaining forms are not annual so much as consequential, and each has its own short clock.

BEN-2 reports a declaration of significant beneficial ownership, within thirty days of receiving the declaration in Form BEN-1.
PAS-3 reports an allotment of shares, within thirty days of the allotment. Any company that has closed a round has filed one.
PAS-6 is a half-yearly reconciliation of share capital audit report, applicable to unlisted public companies.
MGT-14 files resolutions and agreements with the Registrar where the Act requires it, within thirty days.
DIR-12 reports the appointment, resignation or change in designation of a director, within thirty days.
CHG-1 and CHG-9 register the creation or modification of a charge, ordinarily within thirty days of creation. Any company with secured debt has this on its file.
CSR-2 is the corporate social responsibility report, filed as an addendum to AOC-4 by companies within the section 135 thresholds. Its due date has been reset by amendment in several recent years, so confirm the current year's date rather than carrying forward last year's.

Form	Triggered by	Due
DPT-3	Any deposits or exempted receipts, including director and shareholder loans	30 June (extended to 31 July for FY 2025-26)
MSME-1	Payments to MSME suppliers outstanding beyond 45 days	30 April and 31 October, half-yearly
DIR-3 KYC Web	Holding a DIN; or a change of mobile, email or address	30 June every third year (next 30 June 2028); 30 days for a change
PAS-3	Allotment of shares	30 days from allotment
CHG-1 / CHG-9	Creation or modification of a charge	Ordinarily 30 days from creation

The first year runs on a different calendar

A company incorporated during FY 2025-26 does not simply join the cycle above. Its first year carries three dates the ongoing calendar has never heard of, and one of them can leave the company legally unable to trade.

The first is the financial year itself. Section 2(41) fixes the year end at 31 March, except that a company incorporated on or after 1 January takes its first year to 31 March of the following year. Incorporate on 20 January 2026 and your first financial year runs to 31 March 2027, not 31 March 2026. Nothing is due this season at all.

The second is Form INC-20A, the declaration of commencement of business under section 10A, due within 180 days of incorporation. Until it is filed the company cannot lawfully commence business or exercise borrowing powers. It is the most commonly missed filing in the whole calendar, because it looks like the tail end of the registration paperwork rather than the start of the compliance one.

The third is the first auditor. The board appoints within thirty days of incorporation; if it does not, the members appoint within ninety days at an extraordinary general meeting. ADT-1 follows within fifteen days of the appointment. And the first AGM sits within nine months of the close of the first financial year, with no extension available.

If any of that is still ahead of you, the mechanics of the incorporation itself, the documents, the fees and the timeline, are covered separately in our guide to company registration in India, and the question of which structure you should have chosen in the first place in private limited, LLP and OPC compared. Foreign-owned entities carry an additional layer, set out in company registration for foreign founders.

LLPs file on a calendar of their own

An LLP is not a company and does not run the company calendar. It has no AGM, so nothing hangs off a meeting date, and both of its annual filings sit on fixed dates.

Form 11, the annual return, is due by 30 May. Form 8, the statement of account and solvency, is due by 30 October. Neither moves with anything the partners do, which makes the LLP calendar simpler to run and easier to forget.

Audit is not automatic. An LLP needs its accounts audited only where turnover exceeds Rs 40 lakh or contribution exceeds Rs 25 lakh in a financial year. Below both thresholds the designated partners certify Form 8 themselves.

The penalty position is the part worth knowing before you pick the structure. Late filing of Form 8 or Form 11 attracts Rs 100 per day per form, running from the due date, with no upper cap. An LLP that has quietly not filed for four years is looking at a six-figure additional fee per form, which is a common and unwelcome discovery during a conversion or a sale.

What a missed ROC date actually costs

The cost is not one number. It is three separate liabilities that stack, plus a fourth consequence that lands on people rather than on the company.

The additional fee, which has no ceiling

Under section 403 and the Companies (Registration Offices and Fees) Rules, 2014, late filing of the annual forms attracts an additional fee of Rs 100 per day per form. Not per filing round. Per form. AOC-4 and MGT-7 late together accrue Rs 200 a day between them.

There is no maximum. A company two years late on both forms has accumulated roughly Rs 146,000 in additional fee alone before anyone has looked at whether a penalty is also due. For forms outside the annual set the additional fee runs on a multiplier instead, rising in slabs from twice the normal fee for a short delay to twelve times for a long one.

The penalty, which is a separate bill

The additional fee is the price of filing late. The penalty is the price of having been late, and an adjudicating officer levies it separately.

Section 92(5) makes a company that fails to file its annual return liable to a penalty of Rs 10,000, with a further Rs 100 for each day the failure continues, subject to a maximum of Rs 2 lakh for the company and Rs 50,000 for each officer in default. Section 137(3) mirrors that for the financial statements. Officers are liable in their own names, not out of the company's account.

For an OPC, a small company or a DPIIT-recognised start-up, section 446B halves those figures, capped at Rs 2 lakh for the company and Rs 1 lakh for an officer. Halved is not waived.

Three years of silence costs five years of directorship

Section 164(2) is the provision that turns a filing problem into a personal one. Where a company has not filed its financial statements or annual returns for a continuous period of three financial years, every person who was a director during that period is disqualified from being reappointed in that company, or appointed in any other company, for five years.

Read the ratio again. Three years of default, five years of disqualification, and it attaches to the individual across every board they sit on. The company is also required to file Form DIR-9 naming the directors of the default period, within thirty days of the failure, and officers who do not are themselves officers in default.

And then the company gets struck off

Section 248 lets the Registrar remove a company's name from the register where it has not commenced business within a year of incorporation, or has not carried on business for two immediately preceding financial years without applying for dormant status. A long filing silence is precisely the signal the Registrar acts on. Restoration is a tribunal application, and it costs more than every year of compliance it replaced.

Working the calendar backwards so nothing slips

Compliance failures are almost never decisions. They are the last item in a chain that started with books that were not closed on time. Which means the fix sits upstream of the calendar rather than inside it.

Work backwards from the AGM date you choose rather than forwards from the year end. Pick a date, then count back: the notice needs twenty-one clear days, the board meeting that approves the accounts precedes the notice, the auditor needs the trial balance and confirmations before that, and the books are closed before the auditor gets them. A 15 August AGM means closed books by roughly the end of June. That is the real deadline, and it appears on no ROC calendar anywhere.

Four habits do most of the work:

Fix the AGM date in the first board meeting of the financial year, not in August. Every other date derives from it automatically.
Close the books monthly rather than annually. A company running a disciplined monthly close has an audit-ready trial balance in April, not August.
Keep a register of what actually applies to you rather than a generic calendar. Whether DPT-3 and MSME-1 are in scope is knowable in April from facts you already have.
Check your small company status each year against the Rs 10 crore and Rs 100 crore thresholds before you pick the annual return form, not after.

And keep the ROC calendar separate in your head from the tax one. They share inputs and share nothing else: different authority, different portal, different dates, different penalties. The income-tax side is set out in our guide to the new Income Tax Act for 2026-27.

If the bottleneck is the books rather than the filings, that is the thing to fix first. Outsource360 runs business registration and compliance alongside outsourced bookkeeping, so the trial balance is closed and audit-ready before the AGM rather than after it. Book a consultation if that is the trade you want to make.

Frequently asked questions

What is the ROC compliance calendar for FY 2025-26?

For a company with a 31 March year end, the AGM is due by 30 September 2026, AOC-4 within thirty days of that meeting, and MGT-7 or MGT-7A within sixty days. If the AGM runs to the last permitted day, those fall on 30 October and 29 November 2026. Fixed-date filings sit alongside: DPT-3 by 30 June, extended to 31 July for FY 2025-26, and MSME-1 by 30 April and 31 October.

Is AOC-4 always due on 30 October?

No, and this is the most common misreading of the calendar. AOC-4 is due within thirty days of the AGM. The 30 October figure assumes the AGM was held on the very last permitted day. An AGM on 12 August makes AOC-4 due on 11 September.

What is the annual compliance for a private limited company in India?

At minimum: hold the AGM, file AOC-4 with the audited financial statements and the directors' report, file MGT-7 or MGT-7A as the annual return, and file ADT-1 for the auditor. Add DPT-3 if the company has taken any loan or deposit, including from a director, and MSME-1 if MSME suppliers have been paid beyond forty-five days. Board meetings and statutory registers are required but are not filings.

Do I still have to file DIR-3 KYC by 30 September 2026?

Almost certainly not. Director KYC moved from annual to once every three years with effect from 31 March 2026. The Ministry has confirmed that directors already KYC compliant are next due on 30 June 2028. A separate thirty-day obligation applies if your mobile number, email address or residential address changes.

What is the difference between MGT-7 and MGT-7A?

MGT-7A is the abridged annual return, filed by one person companies and small companies. MGT-7 is the full return, filed by everyone else. Since 1 December 2025 the small company thresholds are Rs 10 crore of paid-up capital and Rs 100 crore of turnover, so companies that filed MGT-7 last year may be eligible for MGT-7A this year.

Is my company still a small company after the December 2025 change?

Check both tests. Paid-up capital must not exceed Rs 10 crore and turnover for the immediately preceding financial year must not exceed Rs 100 crore. Public companies, holding and subsidiary companies, section 8 companies and companies governed by a special Act are excluded regardless of size.

What is the penalty for late filing of AOC-4 and MGT-7?

Two separate amounts. An additional fee of Rs 100 per day per form runs from the due date with no upper limit. On top of that, sections 92(5) and 137(3) provide a penalty of Rs 10,000 plus Rs 100 per day of continuing default, capped at Rs 2 lakh for the company and Rs 50,000 for each officer in default. Section 446B halves the penalty for OPCs, small companies and DPIIT-recognised start-ups.

Can I still use the CCFS 2026 scheme to clear old filings?

Until 15 September 2026. General Circular No. 04/2026 of 31 August 2026 extended the scheme to that date, and it allows pending annual filings at ten percent of the accumulated additional fee. No separate immunity application is needed; the V3 portal applies the reduced fee automatically.

What happens if a company does not file for three years?

Every director during that period is disqualified for five years under section 164(2), across every company they are on the board of, not just the defaulting one. The company itself becomes a candidate for strike off under section 248, and restoration then requires a tribunal application.

Does an OPC have to hold an AGM?

No. A one person company is exempt, so its dates are fixed rather than derived. AOC-4 is due within 180 days of the year end, which is 27 September 2026 for FY 2025-26, and MGT-7A within sixty days of the end of the six-month AGM window, which is 29 November 2026.

What are the ROC due dates for an LLP?

Form 11, the annual return, by 30 May. Form 8, the statement of account and solvency, by 30 October. Both are fixed dates with no AGM behind them. Late filing is Rs 100 per day per form with no cap.

Does an LLP need an audit?

Only where turnover exceeds Rs 40 lakh or contribution exceeds Rs 25 lakh in the financial year. Below both, the designated partners certify Form 8 themselves.

Can the AGM deadline be extended?

Yes, for every AGM except the first. Apply to the Registrar in Form GNL-1 for up to three months on special reasons, and apply before the deadline rather than after it. The first AGM, due within nine months of the close of the first financial year, cannot be extended.

Do I need to file INC-20A?

If your company was incorporated with share capital on or after 2 November 2018, yes, within 180 days of incorporation. Until it is filed the company cannot lawfully commence business or exercise borrowing powers.

Which portal do I file on now that V2 is gone?

MCA V3 only. The legacy MCA21 V2 portal was decommissioned on 30 June 2026. Expect the annual forms as web forms rather than PDFs, and expect to attach a photograph of the registered office with GPS coordinates matching the registered address.

Is DPT-3 required if the only loan is from a director?

Usually yes. Money from a director is an exempted receipt rather than a deposit, and exempted receipts are still reported in DPT-3. The exemption is from the deposit rules, not from the return.

Does DPIIT recognition change anything on the ROC calendar?

Not the dates. It does change the penalties: section 446B halves the penalty for a DPIIT-recognised start-up company, subject to a cap of Rs 2 lakh for the company and Rs 1 lakh for an officer in default. The filing obligations themselves are identical.

References

Companies Act, 2013: sections 2(41), 2(85), 10A, 88, 92, 96, 134, 135, 137, 139, 164(2), 173, 248, 403, 446B and 460.
Companies (Specification of Definitions Details) Amendment Rules, 2025, G.S.R. 880(E) dated 1 December 2025, revising the small company thresholds in rule 2(1)(t).
Companies (Appointment and Qualification of Directors) Amendment Rules, 2025, G.S.R. 943(E) dated 31 December 2025, effective 31 March 2026, amending rule 12A.
Ministry of Corporate Affairs press release, MCA replaces Annual KYC requirements under the Companies Act, 2013 with abridged KYC requirements once in three years, Press Information Bureau, 1 January 2026.
MCA General Circular No. 01/2026 dated 24 February 2026, introducing the Companies Compliance Facilitation Scheme, 2026.
MCA General Circular No. 02/2026 dated 19 June 2026, extending DPT-3 for FY 2025-26 to 31 July 2026.
MCA General Circular No. 03/2026 dated 8 July 2026, extending CCFS-2026 to 31 August 2026.
MCA General Circular No. 04/2026 dated 31 August 2026, extending CCFS-2026 to 15 September 2026.
Companies (Accounts) Rules, 2014; Companies (Management and Administration) Rules, 2014; Companies (Acceptance of Deposits) Rules, 2014, rule 16; Companies (Registration Offices and Fees) Rules, 2014.
Limited Liability Partnership Act, 2008 and the LLP Rules, 2009, for Form 8 and Form 11.
Ministry of Corporate Affairs, mca.gov.in, for the V3 filing portal, the current form set and the gazette notifications cited above.

Disclaimer

This article is for educational and general business information purposes only and does not constitute professional legal, financial, or tax advice. Filing obligations, due dates and thresholds under the Companies Act, 2013 change by notification and circular, sometimes mid-season, and the correct dates for any specific company depend on its incorporation date, financial year, size and activity during the year. Consult a qualified company secretary, chartered accountant or advocate before acting on any date, form or threshold set out here.