DPT-3 e-Form: Due Date

DPT-3 e-Form: Due Date — Complete Filing Guide for FY 2025-26

The short answer: DPT-3, the annual return of deposits and exempt deposits, must be filed by 30 June 2026 for Financial Year 2025-26 (the year ended 31 March 2026). Every company other than a Government company — including companies that have never solicited public deposits — must file if they carry any outstanding amount that falls within the deposit rules. Missing this deadline exposes the company and its directors to graded additional fees on MCA V3, monetary penalties under the Companies Act 2013, and in serious cases, prosecution. Lock your data by mid-April, obtain director declarations and the auditor's certificate by early June, and treat 20 June as your internal hard deadline, not 30 June.

What Is DPT-3 and Who Has to File It

DPT-3 is an electronic form mandated under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014 ("the Deposit Rules"), read with Sections 73 and 76 of the Companies Act 2013. Its purpose is twofold: to disclose deposits actually held by the company, and to disclose amounts not treated as deposits (commonly called exempt deposits) — money received from banks, directors, or group companies that falls outside the statutory deposit definition but still requires annual disclosure.

Who must file:

• Private limited companies
• Public limited companies (listed and unlisted)
• One Person Companies (OPCs)
• Section 8 companies (unless specifically exempted by a government notification)
• Subsidiaries of foreign companies incorporated in India

Who is exempt:

Government companies as defined under Section 2(45) of the Companies Act 2013 — those in which at least 51% of paid-up share capital is held by the Central Government, one or more State Governments, or both, are fully exempt from the Deposit Rules and do not file DPT-3.

If your balance is nil: The MCA has not granted a blanket exemption for companies with zero outstanding deposits. If your company carries any inter-corporate loan, director loan, bank facility, or security deposit — even if every rupee of it is "exempt" — you must still file DPT-3 disclosing those exempt amounts. A nil-deposit return is perfectly valid and extremely common. Choosing not to file because you assume everything is exempt is not a defensible position during an ROC inspection.

The Statutory Due Date — And Why Extensions Should Never Be Assumed

The due date for DPT-3 is fixed by Rule 16: the form must be filed on or before 30 June of every financial year, covering amounts outstanding as on 31 March of the immediately preceding year.

The MCA has issued one-time extensions in exceptional years — notably during the pandemic period. Those relaxations were specific, time-limited, and came with their own conditions. They should never be projected forward or assumed. Build your compliance calendar around 30 June as the hard statutory deadline, with an internal soft deadline of 20 June to absorb portal outages, DSC renewal delays, and last-minute auditor queries.

One practical point worth flagging: DPT-3 does not require the statutory audit to be complete. You need the closing balance of deposits and exempt deposits as on 31 March, which can be extracted from the books before the auditor issues the audit report. Many companies unnecessarily delay DPT-3 because the annual accounts are not finalised — this is both avoidable and costly.

Decoding "Deposits" vs "Exempt Deposits" — The Classification That Matters Most

This is the section of DPT-3 preparation where companies most frequently make errors — and where the errors carry the most serious consequences. The form splits outstanding amounts into two schedules. Mis-classifying an actual deposit as an exempt amount can transform a routine compliance default into a far graver offence.

What qualifies as a "deposit" (actual deposits — Part II of the form)

Under Rule 2(1)(c) of the Deposit Rules, "deposit" has a deliberately wide residual definition: any receipt of money by way of loan or otherwise. The rule then carves out specific exclusions. If your receipt does not fit any carve-out, it is a deposit, regardless of what you call it in your books.

Items that are treated as deposits:

• Unsecured loans from the general public
• Amounts received from members of a public company beyond prescribed thresholds
• Compulsorily Convertible Debentures (CCDs) where conversion has been deferred beyond 10 years from the date of issuance
• Optionally Convertible Debentures that remain unconverted beyond 10 years
• Trade advances received for supply of goods or services that are not adjusted within 365 days of receipt

What qualifies as an "exempt deposit" (amounts not treated as deposit — Part III of the form)

The following categories are excluded from the definition of deposit. They appear in the exempt schedule but must still be disclosed:

1. Director loans — amounts received from a director of the company, provided the director has filed a declaration with the company (and the company has filed it with the ROC where required) confirming the money is not borrowed. A fresh declaration is needed for each financial year.
2. Relative loans in private companies — amounts received from a relative of a director of a private company (not available to public companies).
3. Inter-corporate loans — amounts received from a holding company, subsidiary company, or fellow subsidiary. Note: amounts from an associate company or a sister concern that is not in a holding-subsidiary relationship do not automatically qualify.
4. Loans from banks and scheduled financial institutions (FIs) — including loans from NBFCs classified as systematically important, External Commercial Borrowings (ECBs) in prescribed forms, and commercial paper issued per RBI guidelines.
5. Employee security deposits — amounts received as security deposit from an employee not exceeding the annual salary of that employee.
6. Trade advances adjusted within 365 days — advances received against supply of goods or rendering of services, refunded or adjusted within 365 days of receipt.

The 365-day trade advance trap: This is the most common reclassification trigger in practice. If an advance was received on 1 June 2024 and the goods were neither supplied nor the advance refunded by 31 May 2025, it crossed the 365-day threshold before 31 March 2026 and is legally a deposit as on that date. Run an ageing report on all advances received, sorted by original receipt date. Flag every item older than 365 days as on 31 March 2026 before you open the DPT-3 form.

Choosing the Right DPT-3 Variant

When you access DPT-3 on MCA V3 (mca.gov.in), the form asks you to select the purpose of filing:

The overwhelming majority of private limited companies file the "Return of Exempt Deposits" variant, because their only liabilities are director loans (with declarations), bank working capital loans, and inter-corporate borrowings — all exempt. They have never accepted public deposits.

If your company has even one amount that qualifies as an actual deposit — including a stale trade advance that crossed the 365-day line — you must select "both" or "Return of Deposits" as appropriate.

When the auditor's certificate is required

A certificate from the statutory auditor confirming the outstanding balance is mandatory when filing a Return of Deposits (actual deposits). The certificate is not a statutory requirement for the exempt-deposits-only return, but prudent practice is to have the auditor review the exempt schedule as well, particularly the classification of advances. Do not approach the auditor for this certificate on 28 June — build it into your engagement letter as a required deliverable with a 10 June deadline.

Documents and Data You Need Before Opening the Portal

Prepare the following before starting the filing session. Attempting to gather data mid-session leads to portal time-outs and partially saved drafts that corrupt on re-opening.

1. Final trial balance as on 31 March 2026 — focus on the liabilities side: loan accounts, advance from customer accounts, security deposit liabilities.
2. Loan agreements and board resolutions for each director loan, inter-corporate loan, and bank facility.
3. Director declarations — one per director lending money to the company, signed and dated in FY 2025-26. These are separate from the board resolution.
4. Ageing schedule of trade advances received — prepared from the debtors/advances sub-ledger, flagging any item older than 365 days as on 31 March 2026.
5. Bank sanction letters confirming each facility is from a scheduled bank or notified financial institution (supports the exemption classification in Part III).
6. Auditor's certificate on deposits if actual deposits are being reported.
7. Valid Class 3 DSC of the authorised director, enrolled on MCA V3. Check the DSC expiry date at least two weeks before the filing date; renewal takes 2–5 working days.
8. Company's CIN, PAN, and authorised signatory details — pre-populate these from your MCA master data.

Step-by-Step Filing Workflow on MCA V3

1. Log in to mca.gov.in (MCA V3 portal) using the company's registered user credentials.
2. Navigate to MCA Services → E-Filing → Company Forms Filing.
3. Search for "DPT-3" in the forms library.
4. Enter the CIN; the portal auto-populates company name, registered address, and authorised capital. Verify these against your MCA master data.
5. Select the purpose of return (deposits / exempt deposits / both) based on your classification exercise.
6. Fill Part I — general particulars: CIN, financial year (select "2025-26"), date of incorporation, main objects/nature of business.
7. Fill Part II (deposits schedule) if applicable — opening balance as on 1 April 2025, additions during FY 2025-26, repayments, and closing balance as on 31 March 2026, broken down by category (from public, from members, from directors, etc.).
8. Fill Part III (exempt deposits schedule) — map each outstanding amount to its correct sub-category line item: director loans, inter-corporate loans, bank/FI loans, employee security deposits, trade advances, etc.
9. Upload attachments — auditor's certificate (PDF, maximum 6 MB) if required; optional working documents.
10. Affix DSC of the director using the MCA DSC utility. Ensure the USB token driver is current; MCA V3 requires a version compatible with your browser.
11. Review the system-computed fee based on paid-up share capital. Confirm the amount before proceeding to payment.
12. Pay online via net banking or NEFT on the MCA payment gateway. Download the payment challan immediately.
13. Save the SRN (Service Request Number) and the acknowledgement receipt. These are your proof of compliance.

Allow 60–90 minutes for a first-time filing and 30–45 minutes if your data is clean and the DSC is working. Never start a filing session after 5:00 PM on the due date — portal load spikes as deadlines approach.

Penalties for Late or Non-Filing — The Numbers You Need to Know

MCA portal additional fee (graded by delay)

Once 30 June passes, the MCA V3 portal automatically calculates an additional fee on top of the normal statutory fee. The normal fee is determined by paid-up share capital (as notified under MCA's fee schedule). The additional fee is a multiple of that normal fee:

The portal additional fee is relatively modest in rupee terms; it is the statutory penalty exposure that warrants attention.

Statutory penalty — exempt deposits only (Section 450)

Where the company has not accepted actual public deposits and the default is simply non-filing of the exempt-deposits return, the penalty falls under Section 450 of the Companies Act (residual penalty for non-compliance with rules):

• Company: fine up to Rs. 10,000, plus Rs. 1,000 per day for each day the default continues
• Every officer in default: fine up to Rs. 10,000, plus Rs. 1,000 per day

For a 200-day delay: Rs. 10,000 + (200 × Rs. 1,000) = Rs. 2,10,000 per officer in default. With two directors, that is Rs. 4,20,000 in combined statutory exposure — for a form that takes an afternoon to file.

Statutory penalty — actual deposit defaults (Section 76A)

Where the company has accepted actual deposits without complying with the Deposit Rules, Section 76A applies — the harshest provision in the deposit compliance framework:

• Company: fine not less than Rs. 1 crore, extendable to Rs. 10 crore
• Every officer in default: imprisonment of up to 7 years, AND/OR fine not less than Rs. 25 lakhs, extendable to Rs. 2 crore

Since the Companies (Amendment) Act 2019, the Registrar of Companies has power to adjudicate monetary penalties without referring the matter to a court. ROC offices have been active in issuing adjudication notices for DPT-3 non-compliance. A penalty adjudication order can be appealed to the Regional Director, but that process involves time, legal costs, and management distraction — none of which is justified when the underlying compliance is a single annual form.

Worked Example: Mapping a Trial Balance to DPT-3 Categories

Company: Aryan Fabricators Private Limited, registered in Maharashtra. FY 2025-26.

Outstanding credit balances as on 31 March 2026:

Filing decision: Aryan Fabricators must select "Return of both Deposits and Exempt Deposits" because the stale customer advance (Rs. 8 lakhs) and the sister-concern loan (Rs. 12 lakhs, subject to auditor confirmation) constitute actual deposits requiring disclosure in Part II. The auditor's certificate is mandatory.

Penalty scenario if filed 120 days late (28 October 2026 instead of 30 June 2026):

• MCA additional fee multiplier (91–180 day bracket): 10×
• Normal fee for paid-up capital of Rs. 20 lakhs: Rs. 400 (as notified)
• Additional MCA fee: Rs. 4,000
• Section 450 statutory penalty per officer: Rs. 10,000 + (120 × Rs. 1,000) = Rs. 1,30,000
• Two directors in default: Rs. 2,60,000 in statutory exposure

Total compliance cost of a 120-day delay: approximately Rs. 2,64,000 — versus an afternoon of work to file on time.

Common Mistakes — and How to Avoid Them

1. Treating director loans as automatically exempt without a fresh declaration

The director loan exemption requires a written declaration, renewed each financial year, that the money is not borrowed. A 2023 declaration does not cover FY 2025-26. If the director borrowed from a bank and on-lent to the company, the declaration is factually false, the exemption collapses, and the amount becomes a deposit. Obtain a fresh declaration and ask the director to confirm the source of funds before 31 March each year.

2. Missing the 365-day reclassification on trade advances

Run a date-sorted ageing report on all advances received from customers and vendors. Any item with a receipt date before 1 April 2025 that has not been adjusted or refunded by 31 March 2026 crossed the 365-day threshold and is legally a deposit. Identify these in April, not in June.

3. Waiting for the full audit before filing DPT-3

The statutory audit and the DPT-3 filing are independent compliance obligations. You need the deposit and exempt deposit balances as on 31 March — that is available from the books well before the auditor issues the audit report. Do not hold back DPT-3 because the accounts are not finalised.

4. Letting the director's DSC expire

Class 3 DSCs are valid for 1–3 years. Renewal takes 2–5 working days. Check the expiry date of every director's DSC in May, not on 28 June. The MCA V3 portal will reject a filing with an expired token, and last-minute DSC renewal is a common cause of late filing.

5. Classifying the sister-concern loan as inter-corporate

The inter-corporate loan exemption covers amounts from a holding company, subsidiary company, or fellow subsidiary. An associate company (where ownership is 20–50%) or a sister concern without a formal group relationship does not qualify. Mapping such loans to the exempt schedule is a mis-disclosure.

6. Filing the wrong variant and submitting a revised return

Selecting "Return of Deposits" when only exempt deposits exist — or vice versa — leads to a mis-stated form. While a revised DPT-3 can be filed, revisions attract scrutiny and additional fees. Get the classification right the first time by completing the mapping exercise from the trial balance before opening the portal.

7. Not archiving the working papers

The SRN and acknowledgement receipt are the minimum you must retain. Preserve the underlying loan agreements, director declarations, ageing schedules, and auditor certificate for at least 8 years. ROC inspection notices for deposit compliance can arrive well after the filing year, and working papers are your defence.

Key Takeaways

• DPT-3 for FY 2025-26 is due by 30 June 2026. Set your internal deadline at 20 June to absorb portal and DSC issues.
• Every company other than a Government company must file — even where the only outstanding amounts are director loans, bank loans, or inter-corporate borrowings (exempt deposits still require disclosure).
• Trade advances older than 365 days as on 31 March 2026 are legally deposits, not exempt amounts. Run an ageing report on all advances received and flag stale items before preparing the form.
• Director loan declarations must be renewed each financial year; a prior-year declaration does not preserve the exemption in FY 2025-26.
• Late filing triggers graded additional fees on MCA V3 (up to 12× normal fee after 180 days) plus statutory penalties: up to Rs. 10,000 + Rs. 1,000/day per officer under Section 450 for exempt-only defaults; Rs. 1–10 crore for the company and Rs. 25 lakhs–Rs. 2 crore per officer under Section 76A where actual deposit defaults are involved.
• The auditor's certificate is mandatory when reporting actual deposits in Part II; initiate that conversation with your statutory auditor by 1 June 2026.
• Retain all DPT-3 working papers — loan agreements, declarations, ageing schedules, payment challans, SRN receipts — for a minimum of 8 years for ROC inspection readiness.