Compliance Calendar of October 2022

Compliance Calendar of October 2026

This post has been updated with FY 2026-27 / AY 2027-28 due dates, current penalty structures and practical guidance. The original 2022 post has been fully revised.

October is India's single most demanding compliance month. Within thirty-one days, your team must close GST quarterly filings, deposit Q2 TDS returns, submit the tax audit report under Section 44AB, file AOC-4 for audited financials on the MCA V3 portal, submit the MSME-1 half-yearly return, and handle EPFO, ESIC and SEBI LODR obligations. Every one of those carries a separate penalty clock. This calendar consolidates all critical due dates for October 2026 — with penalties, step-by-step sequences and the mistakes that routinely derail finance teams.

Why October Is India's Hardest Compliance Month

Three statutory calendars collide simultaneously in October. The GST cycle closes out Q2 (July–September 2026), making October home to both monthly GSTR-3B submissions and the quarterly QRMP filings. The Income Tax cycle demands the Q2 TDS return, the tax audit report for millions of businesses, and the ITR for tax-audit assessees. And the company law cycle hits its annual peak: AOC-4 is tied to the AGM date, MSME-1 closes the half-year, and the MCA V3 portal predictably buckles under load in the final week.

Layered over all of this is the reality that Q2 board meetings for listed entities typically fall in October — consuming CFO and CS bandwidth precisely when both are needed elsewhere. October does not forgive last-minute planning.

GST Due Dates — October 2026

10 October

• GSTR-7 — TDS return under GST (Section 51 of the CGST Act 2017) for September 2026. Applicable to government departments, local authorities and PSUs that deducted GST-TDS on contracts above the prescribed threshold.
• GSTR-8 — TCS return for e-commerce operators (Section 52) for September 2026.

11 October

• GSTR-1 (monthly filers) — Outward supply statement for September 2026. Late fee: Rs. 50 per day (Rs. 25 CGST + Rs. 25 SGST), reduced to Rs. 20 per day for nil returns, subject to the GST Council-notified cap for your turnover slab.

13 October

• GSTR-1 / IFF (QRMP scheme) — Outward supply statement or Invoice Furnishing Facility for the July–September 2026 quarter for QRMP-enrolled taxpayers.
• GSTR-6 — Return for Input Service Distributors (ISDs) for September 2026.

18 October

• CMP-08 — Quarterly challan-cum-statement for composition-scheme taxpayers (Section 10) covering July–September 2026. A delayed CMP-08 attracts both the late fee and interest at 18% per annum on the tax payable from the original due date.

20 October

• GSTR-3B (monthly filers, aggregate turnover above Rs. 5 crore) — Summary return for September 2026. Reconcile your purchase register against GSTR-2B before submitting; ITC claimed in excess of GSTR-2B auto-populated amounts is a standard trigger for scrutiny notices.

22 and 24 October

• GSTR-3B (QRMP filers) — Split by CBIC-notified state category:
• 22 October: Category 1 states (broadly eastern and north-eastern states — check CBIC notification for current grouping)
• 24 October: Category 2 states (broadly western and southern states)

31 October

• ITC-04 — Half-year return for job-work movement of goods (July–September 2026) for principals with annual aggregate turnover above Rs. 5 crore. Principals below that threshold file ITC-04 annually.

Practical GST tip: GSTR-2B for September populates around the 14th. Waiting until then to start reconciliation leaves you four working days before the 20 October GSTR-3B deadline to chase missing supplier invoices — far too little time. Flag unreconciled purchase invoices with your vendors no later than 5 October.

Income Tax and TDS Due Dates — October 2026

7 October

Deposit TDS / TCS for all amounts deducted or collected in September 2026. Delayed deposit attracts interest at 1.5% per month (or part month) from the date of deduction to the date of payment under Section 201(1A) of the Income-tax Act 1961. This interest is not deductible as a business expense, making it doubly painful.

15 October

Form 27EQ — Quarterly TCS return for Q2 FY 2026-27. Late filing attracts a mandatory fee of Rs. 200 per day under Section 234E, subject to the TCS amount as the upper ceiling. A separate discretionary penalty of Rs. 10,000 to Rs. 1,00,000 under Section 271H applies if the return remains unfiled for more than one year from the due date.

30 October

Form 16A — TDS certificate for Q2. Issue to all non-salary deductees — contractors, professionals, interest recipients — within fifteen days of the quarterly return due date. Failure to issue certificates within the prescribed timeline attracts a penalty of Rs. 100 per day under Section 272A(2)(g).

31 October

• Form 24Q / 26Q / 27Q — Quarterly TDS returns for Q2 FY 2026-27:
• 24Q: TDS on salaries
• 26Q: TDS on non-salary domestic payments
• 27Q: TDS on payments to non-residents (DTAA relief claims and lower withholding certificate details must be reflected)

• Income Tax Return (AY 2027-28) — For taxpayers liable to tax audit under Section 44AB. The ITR can only be filed after the tax audit report has been submitted on the income-tax e-filing portal by the auditor.

• Tax Audit Report (Form 3CA-3CD or Form 3CB-3CD) — Section 44AB audit report for AY 2027-28 where CBDT has extended the original 30 September deadline. Confirm current extension notifications on the income-tax e-filing portal; do not assume any extension unless officially notified.

Who requires a tax audit? Businesses with turnover exceeding Rs. 1 crore (Rs. 10 crore where cash receipts and cash payments are each below 5% of total), and professionals with gross receipts exceeding Rs. 50 lakh. Taxpayers declaring income below the presumptive thresholds under Sections 44AD, 44ADA or 44AE may also trigger the audit requirement.

MCA / ROC Filing Deadlines — October 2026

Form ADT-1 — Auditor Appointment (15 October)

Every company that held its AGM on 30 September 2026 must file Form ADT-1 with the Registrar of Companies within 15 days of the AGM, under Section 139(1) of the Companies Act 2013. The form must carry the auditor's written consent, the certificate that conditions under Section 141 are satisfied, and the board resolution approving the appointment. The general MCA V3 additional fee structure under Section 403 applies for late filings.

Form AOC-4 — Filing Audited Financial Statements (29 October)

This is October's highest-risk MCA filing. Under Section 137 of the Companies Act 2013, every company must file audited financial statements within 30 days of the AGM. For companies whose AGM concluded on 30 September 2026, the deadline is 29 October 2026 — not 30 October. The MCA portal counts from the AGM date inclusive; a one-day miscalculation regularly results in ROC notices.

What to attach:

• Board's Report with all annexures (including Secretarial Audit Report where applicable)
• Auditor's Report
• Balance Sheet, Profit & Loss Account, Cash Flow Statement and Notes
• For listed companies and companies with paid-up capital ≥ Rs. 5 crore or turnover ≥ Rs. 100 crore: AOC-4 XBRL with tagged data
• For NBFCs: AOC-4 NBFC

Penalty under Section 137(3):

• Company: Rs. 10,000 fixed + Rs. 100 per day of continuing default, up to a maximum of Rs. 2,00,000
• Managing Director / CFO (or responsible director in their absence): Rs. 10,000 + Rs. 100 per day, up to a maximum of Rs. 50,000 per person
• MCA V3 portal additional filing fees (as notified under Section 403) multiply significantly for delays beyond 60–90 days

Form MSME-1 — Half-Yearly Outstanding Payment Return (30 October)

Under the MCA's Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order, 2019, every company with dues outstanding to Micro or Small Enterprise suppliers for more than 45 days from acceptance of goods or services must file Form MSME-1. The 30 October 2026 deadline covers the half-year ending 30 September 2026 (April–September 2026).

Who must file? Any company — private, public, listed or unlisted — where such dues exist. If no dues are outstanding beyond 45 days, file a nil return anyway; the filing obligation exists regardless.

What to report? Name and PAN of each MSME vendor, amount outstanding, and reason for delay.

Penalty under Section 405(4): Fine not less than Rs. 25,000, extendable to Rs. 3,00,000, for the company and every officer in default. Continuing default attracts an additional fine of Rs. 1,000 to Rs. 10,000 per day.

Half-Yearly Secretarial Compliance (31 October)

Unlisted public companies under the applicable SDD (Secretarial Standards on Dividends) / internal governance norms must submit the half-yearly secretarial compliance certificate by 31 October for the half-year ending 30 September 2026.

EPFO, ESIC and Professional Tax — October 2026

Interest on delayed EPF payments under Section 7Q of the EPF & MP Act 1952 runs at 12% per annum for each day of delay. Damages under Section 14B can add 5% to 25% of the arrears, depending on the period of default. These amounts cannot be reclaimed from employees — they are entirely the employer's cost.

SEBI LODR Deadlines for Listed Entities

The second quarter ending 30 September 2026 triggers the following disclosures to stock exchanges under the SEBI (Listing Obligations and Disclosure Requirements) Regulations 2015:

The Regulation 33 deadline technically falls in November, but the audit committee meeting, limited review engagement and board approval must all be scheduled in October. Companies that leave these items to November invariably miss the 14 November cut-off. Penalty for non-compliance: SEBI can impose up to Rs. 1 crore per instance under Section 15HB of the SEBI Act 1992.

Worked Example: The Real Cost of Three Missed October Deadlines

Take a mid-size private limited company with annual turnover of Rs. 8 crore. The CFO travels for ten days in late October. Three filings slip.

Slip 1: GSTR-3B for September 2026 filed 20 days late

Late fee: Rs. 50/day × 20 days = Rs. 1,000 (Rs. 500 CGST + Rs. 500 SGST), subject to the notified turnover-based cap.

If net tax payable was Rs. 3,00,000, interest at 18% per annum = Rs. 3,00,000 × 18% × 20 ÷ 365 = Rs. 2,959.

Total GST cost for a 20-day slip: approximately Rs. 3,959 — plus a compliance rating mark against the GSTIN.

Slip 2: Form 26Q (non-salary TDS return) filed 45 days late

Late fee under Section 234E: Rs. 200/day × 45 days = Rs. 9,000.

TDS deducted in Q2 was Rs. 80,000. The late fee does not exceed the deducted amount, so the full Rs. 9,000 applies.

If TDS was itself deposited 10 days late: Rs. 80,000 × 1.5% × 1 month = Rs. 1,200 interest under Section 201(1A).

Total TDS cost for this slip: Rs. 10,200 — before any Section 271H penalty for non-filing.

Slip 3: AOC-4 filed 90 days after the AGM date

Target date was 29 October. Filed on 28 January.

Statutory penalty under Section 137(3):

Plus MCA V3 additional filing fees (as notified under Section 403 for 60–90 day delays, which multiply the standard fee several times) and the reputational mark on the company's MCA compliance record.

Three missed filings, one travel trip: total exposure exceeding Rs. 71,000 — for a problem that a first-week October checklist would have prevented entirely.

Common Pitfalls to Avoid in October

1. Starting GSTR-2B reconciliation after the 14th

GSTR-2B for September populates around the 14th. Beginning reconciliation then gives you six working days before the 20 October GSTR-3B deadline. That is not enough time to chase missing supplier invoices, get credit notes raised or resolve tax-rate mismatches. Start flagging gaps by the first week of October so vendors have time to correct their GSTR-1 before the 11th.

2. Treating the tax audit deadline as aspirational

The 31 October date is the last possible date, not the target date. Your auditor needs finalized books, GST-wise revenue data and MSME payment data (now required in Form 3CD). If you share accounts on 25 October and expect a signed audit report by 31 October, you are transferring your scheduling risk to your CA — and Section 44AB penalties (up to 0.5% of turnover or Rs. 1,50,000, whichever is lower) land on the taxpayer, not the auditor. Lock books by 10 October; target report filing by 25 October.

3. Misreading the AOC-4 window as month-end

The 30-day window runs from the AGM date, not from month-end. AGM on 30 September means day 30 is 29 October. Filing on 30 October is a late filing, and the MCA portal will reflect it as such. Always count from the actual AGM date — the portal does.

4. Skipping MSME-1 when dues are nil

The filing obligation under the 2019 MCA Order exists regardless of whether dues are outstanding. A company that procured from MSME vendors during April–September 2026 but cleared all invoices within 45 days still needs to file a nil MSME-1. Non-filing of a nil return attracts the same Section 405(4) penalty as actual non-disclosure.

5. Queuing AOC-4 for the 29th or 30th

MCA V3 portal slowdowns during AOC-4 deadline week are not a rumour — they are a documented annual pattern. Form rejections on day 28 or 29 due to portal errors leave zero buffer. Target AOC-4 submission by 25–27 October. If the form is rejected, you have two to three days to correct and resubmit within the statutory window.

6. Allowing DSC renewals to lapse

Multiple October filings — AOC-4, MSME-1, income tax returns, GST — require a valid Class 3 DSC. If your signing director's or authorised signatory's DSC was obtained in October of a prior year on a three-year cycle, it may expire this month. Check DSC expiry dates during the first week of October, not on the day of filing.

Building Your October Compliance War-Room

You do not need expensive GRC software. A shared, locked-down spreadsheet updated daily is sufficient. The discipline matters more than the tooling.

Step 1 — Populate on 1 October: List every applicable due date, the named owner (not just the designation), the supporting document or data required, the portal or payment channel, and a status column. A due date without a named human owner will not get filed.

Step 2 — Sequence the work calendar:

• 1–5 Oct: Reconcile GSTR-2B; lock purchase register; confirm AGM date and calculate AOC-4 window; audit DSC expiry dates
• 5–7 Oct: Deposit September TDS/TCS; review GSTR-1 completeness; flag supplier invoice gaps
• 8–11 Oct: File GSTR-1; initiate ADT-1 if applicable; issue Regulation 13/27/31 data for listed entities
• 12–15 Oct: Deposit PF and ESIC; file Form 27EQ; LODR disclosures due by 21 October — board secretariat to initiate drafting
• 15–20 Oct: Resolve GSTR-3B ITC differences; deliver finalized books and GST-wise data to auditor
• 20–24 Oct: File GSTR-3B (monthly and QRMP); file QRMP GSTR-1/IFF
• 25 Oct (target): Tax audit report filed by CA; issue Form 16A to deductees
• 25–27 Oct: File AOC-4 and MSME-1 — do not wait for the 29th
• 28–31 Oct: File TDS returns (24Q, 26Q, 27Q); file ITRs for tax-audit assessees; CMP-08 if applicable

Step 3 — Define backup owners: Every filing line must have a secondary owner who independently holds portal login credentials, valid DSC and bank payment access. One person's illness or absence should never cascade into a default.

Step 4 — Store compliance evidence: On every successful submission, download the acknowledgement, SRN (from MCA V3), ARN (from GST portal) or UTR (for tax payments). Store these against each due date in a shared drive folder labeled by year and month. This is your primary defence in any future notice or assessment.

Step 5 — Friday stand-up: A twenty-minute Friday review through all four October weeks surfaces blockers while there is still time to fix them. The finance head should attend; the compliance owner should present status, not just assurances.

Key Takeaways

• GST: Monthly filers — GSTR-1 by 11 October, GSTR-3B by 20 October. QRMP filers — GSTR-1/IFF by 13 October, GSTR-3B by 22 or 24 October. ITC-04 for eligible job-work principals is due 31 October. Begin GSTR-2B reconciliation in the first week, not the second.
• TDS / TCS: Deposit September deductions by 7 October; file Form 27EQ by 15 October; issue Form 16A by 30 October; file 24Q / 26Q / 27Q by 31 October. Section 234E runs at Rs. 200 per day — a 45-day slip on Form 26Q alone costs Rs. 9,000 in mandatory late fees.
• Tax audit and ITR: Lock books by 10 October. Target tax audit report (Form 3CA/3CB-3CD) filing by 25 October. Do not rely on the 31 October extended deadline — it is a backstop, not a planning date.
• AOC-4: Count exactly 30 days from your AGM date. AGM on 30 September means the deadline is 29 October. File by 25–27 October to avoid portal congestion. Penalty under Section 137(3) is Rs. 19,000 for the company and Rs. 19,000 each for the MD and CFO on a 90-day delay — Rs. 57,000 in aggregate.
• MSME-1: Due 30 October for the April–September half-year. File even where no dues are outstanding. Penalty under Section 405(4) starts at Rs. 25,000 and escalates with continuing default.
• Portal strategy: File AOC-4 and MSME-1 by 26–27 October. The MCA V3 portal slows materially on the final two days of every peak-filing period — build in at least a three-day buffer.
• Cross-functional ownership: Name a primary and backup owner (with independent access) for every filing line across GST, TDS, ROC, EPFO/ESIC and HR. A single point of failure in October — an illness, a resignation, an expired DSC — can trigger simultaneous defaults across multiple filings.