Step-by-step Form DPT-3 filing — categories, due date 30 June, process, certifications and penalties for Indian companies in FY 2026-27.
Explaining Form DPT-3 Filing
Form DPT-3 is the MCA's primary window into a company's entire borrowing profile — deposits and non-deposits alike. Governed by Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, every company incorporated under the Companies Act, 2013 — Government companies excepted — must file it by 30 June each year for its position as on the preceding 31 March. For FY 2026-27, the reporting date is 31 March 2026 and the filing deadline is 30 June 2026. Non-filing exposes the company to penalties of up to Rs. 2 lakh and every officer in default to up to Rs. 50,000 separately under Section 450 of the Act.
What Is Form DPT-3 — and Why the 2019 Amendment Changed Everything
Form DPT-3 was originally conceived as a deposit-return form for companies that had accepted money from the public or members. Its mandate was narrow: tell the RoC how much you hold, from whom, and on what terms.
That changed with the Companies (Acceptance of Deposits) Amendment Rules, 2019, notified on 22 January 2019. The amendment required every company — not just deposit-accepting ones — to file an annual return disclosing outstanding receipts of money or loans that are not classified as deposits as on 31 March. The effect was sweeping. Even a wholly privately-funded startup with a single bank term loan suddenly had a DPT-3 obligation.
Why did MCA do this? Regulatory visibility. Before 2019, the RoC had no consolidated data on how much money Indian companies had borrowed outside the formal deposit framework. DPT-3 now gives it that picture — and that picture feeds into systemic risk monitoring, insolvency early-warning, and enforcement targeting.
The practical consequence for you: if your company has any outstanding loan, advance, debenture, or inter-corporate borrowing as on 31 March — even a director's unsecured loan of Rs. 1 lakh — you have a DPT-3 obligation. A nil-liability position still warrants filing, because it documents that you actively reviewed your borrowing ledgers and found nothing reportable. That active verification is what auditors, lenders, and investors look for.
Who Must File and Who Is Exempt
Companies that must file
DPT-3 applies to:
- Private limited companies (including small companies and start-ups under the DPIIT framework)
- Public limited companies
- One Person Companies (OPCs)
- Section 8 companies (licensed not-for-profit companies)
- Producer companies
- Nidhi companies (for borrowings outside the Nidhi-specific framework)
Companies that are exempt
Government companies as defined under Section 2(45) of the Companies Act, 2013 are excluded from the Companies (Acceptance of Deposits) Rules, 2014 and do not file DPT-3. A company qualifies as a Government company when not less than 51 per cent of its paid-up share capital is held by the Central Government, one or more State Governments, or both.
Foreign companies registered under Section 380 of the Act have separate compliance obligations and do not file DPT-3 on MCA V3.
The nil-filing question
There is no express statutory requirement to file DPT-3 when a company genuinely has zero deposits and zero outstanding non-deposit receipts as on 31 March. In practice, however, three reasons make a nil return the right call:
- RoC systems flag companies with no DPT-3 on record regardless of the reason.
- A nil return is a positive assertion — it tells the RoC and your auditor that you actively reviewed the ledgers and found nothing reportable.
- During investor due diligence, an unbroken DPT-3 filing history is standard expectation. A missing year raises a flag even when the explanation is innocent.
File a nil return. The professional fee is marginal, and the documentation value is not.
What Goes Inside Form DPT-3: The Four Return Categories
When you open Form DPT-3 on MCA V3, the first substantive choice is the category of return. Getting this wrong determines which subsequent fields appear and what certifications are required — a category mismatch is a material error, not a clerical one.
Category 1 — One-time return
Used for outstanding non-deposit receipts as on a date specifically notified by MCA (the 2019 amendment required a one-time return for balances as on 22 January 2019). This category is largely historical. Unless MCA issues a fresh specific-date notification, you will not use Category 1 for FY 2026-27 filings.
Category 2 — Annual return of deposits
Used by companies that have accepted deposits — as defined under Section 2(31) of the Companies Act, 2013 read with Rule 2(1)(b) of the Deposit Rules — during the year or have deposits outstanding as on 31 March. This category requires the statutory auditor's certificate confirming that the deposits have been accepted in compliance with Sections 73 to 76 of the Act and the Deposit Rules.
Category 3 — Annual return of outstanding non-deposit receipts
Used when a company has no actual deposits but has outstanding loans, advances, or other money receipts that fall within the exemptions to the deposit definition as on 31 March. The certificate here is issued by a practising Chartered Accountant, Company Secretary, or Cost Accountant — not necessarily the statutory auditor.
Category 4 — Combined return
Used when a company has both actual deposits and outstanding non-deposit receipts as on 31 March. It requires both the auditor's deposit certificate and the practising professional's non-deposit certificate.
The reality for most private companies: Category 3 or Category 4. Bank overdrafts, director's loans, and inter-corporate advances — all of which are non-deposit receipts — are far more common than actual public deposits. Even so, a company with both a director's loan and a fixed deposit scheme from members must file Category 4, not Category 3.
The Deposit vs. Non-Deposit Divide: Getting Classification Right
Misclassification is the single largest source of DPT-3 errors and the most likely to attract an RoC query. Here is a working classification framework.
What counts as a deposit
A "deposit" means any receipt of money by way of deposit or loan or in any other form, as defined under Section 2(31) read with Rule 2(1)(b) of the Deposit Rules — subject to the exclusions in Rule 2(1)(c).
What does NOT count as a deposit (key Rule 2(1)(c) exclusions)
| Receipt type | Condition for exclusion |
|---|---|
| Loans from scheduled banks and financial institutions | Any amount; no cap or condition |
| Unsecured loans from directors | Director must furnish a written declaration that the amount is not sourced by borrowing or accepting deposits from others |
| Inter-corporate loans | Loan received from another company (holding, subsidiary, associate, or unrelated) |
| External Commercial Borrowings | Raised in compliance with FEMA guidelines |
| Listed debentures | Debentures listed on a recognised stock exchange |
| Security deposits from employees | In the ordinary course of employment |
| Share application money | Pending allotment, within the time frame prescribed by SEBI / Companies Act |
Critical point: Being "not a deposit" does not mean "not reportable." Every excluded item that is outstanding as on 31 March still appears in Form DPT-3 as an outstanding non-deposit receipt. The exclusion only determines which section of the form the amount falls in — it does not grant an exemption from disclosure.
The director loan declaration — the most litigated classification issue
A director's unsecured loan is excluded from the deposit definition only if the director furnishes the written declaration in the format prescribed under the Deposit Rules before the loan is drawn into the company's account. If no such declaration exists:
- The amount may be reclassified as a deposit during an RoC inspection or audit.
- If deposits breach the prescribed limits, full deposit-compliance machinery applies: credit rating, deposit insurance, and creation of the Deposit Repayment Reserve (DRR) of 20 per cent of deposits maturing in the following financial year under Rule 13 of the Deposit Rules.
- Retroactive declarations carry no statutory recognition.
Obtain the declaration before the funds hit the bank account, not the week before the DPT-3 deadline. Build this step into your loan-acceptance standard operating procedure.
Customer advances that age past their fulfilment date
Advances received against contracts for the supply of goods or services that remain unadjusted beyond the period agreed in the contract — or beyond 365 days where no period is specified — risk reclassification as deposits. Screen your "advance from customers" ledger before filing DPT-3. Any credit older than 365 days with no corresponding delivery warrants specific classification advice before the amount is placed in the non-deposit bucket.
Documents You Must Assemble Before You Log In
Do not open MCA V3 until every item in this list is on your desk. Filing with missing attachments or figures that do not match your documents is a common reason for RoC queries and SRN rejections.
- Audited financial statements for FY 2026-27 — balance sheet, profit & loss account, and the borrowings note specifically
- Loan-wise outstanding schedule as on 31 March 2026 — lender name, PAN where available, principal outstanding, interest accrued, nature of loan (secured/unsecured, term/demand)
- Written balance confirmations from each lender as on 31 March 2026 — signed, dated, and on the lender's letterhead
- Director declarations in the prescribed format for every director's loan appearing in the books
- Board resolution authorising a specific director to sign Form DPT-3 and identifying the certifying professional
- Auditor's certificate (for the deposits component — Categories 2 and 4) in the format prescribed under the Deposit Rules, with UDIN
- CA / CS / CMA certificate for the non-deposit component (Categories 3 and 4), with membership number and UDIN from the respective Institute's self-service portal
- List of depositors (if applicable) — name, address, PAN, amount, rate of interest, maturity date
- Active Class 3 DSC of the signing director, registered on MCA V3
- Active Class 3 DSC of the certifying professional, registered with the Institute and the MCA portal
Step-by-Step DPT-3 Filing on MCA V3
Step 1: Reconcile loan ledgers
Extract every credit balance that represents money received from an external party — banks, directors, shareholders, related companies, debenture holders, fixed deposit holders. Reconcile each balance against the lender's confirmation and bank statement as on 31 March 2026. Match these to the borrowings note in your audited financials. Resolve all discrepancies before moving forward.
Step 2: Classify each outstanding receipt
Tag every item as (a) deposit, (b) exempted non-deposit receipt, or (c) not within scope (for example, trade payables to vendors for goods received are not receipts of money in the deposit-rule sense). Most private companies will have only category (b) items.
Step 3: Determine your return category
Deposits only → Category 2. Non-deposit receipts only → Category 3. Both → Category 4. Neither → file a nil Category 3 return with zeros and attach a brief management declaration.
Step 4: Brief your certifying professional early
Engage your statutory auditor (for the deposit certificate) or your practising CA / CS / CMA (for the non-deposit certificate) in April, immediately after the financial statements are finalised. Provide the reconciled schedule, lender confirmations, and director declarations. Allow two to three weeks for review and UDIN generation — rushing this in the last week of June is a preventable risk.
Step 5: Log in to MCA V3 and select Form DPT-3
Navigate to mca.gov.in → Business User → select company → e-Forms → DPT-3. The form pre-fills the CIN, company name, registered address, and date of incorporation from the company master data. Verify these before proceeding; any mismatch with your physical records should be flagged to the RoC separately.
Step 6: Enter the financial particulars
Input the outstanding amount under each head matching your return category. Every figure must tie directly to the reconciled schedule from Step 1 and to the borrowings note in your AOC-4 financial statements. Cross-form consistency is a standard part of RoC processing.
Step 7: Attach supporting documents
Upload in PDF format. Stay within MCA V3's per-file and total-attachment size limits. Documents to attach: auditor's or professional's certificate, director declarations, list of depositors if applicable, and the board resolution (strongly recommended as a best-practice attachment even if not mandated).
Step 8: Affix DSCs
Apply the signing director's DSC and the certifying professional's DSC through the MCA V3 signing utility. Both must be active, not expired or revoked. Test the DSC functionality at least 48 hours before 30 June. DSC renewal on 29 or 30 June is the most common avoidable last-minute crisis in annual compliance.
Step 9: Submit, pay, and collect the SRN
Pay the prescribed fee (based on authorised share capital under the Companies (Registration Offices and Fees) Rules, 2014) via the MCA payment gateway. The system generates a Service Request Number (SRN) on submission. Record this immediately — it is your proof of filing and the reference number for all future correspondence on this form.
Step 10: Download the acknowledgement
MCA V3 typically processes the form within 24 to 72 hours. Download the approved/registered form and the challan. Preserve both in your company's statutory records file alongside the board resolution and certificates.
Worked Example: What a Late Filing Actually Costs
Scenario: Zenpath Technologies Private Limited, a software services company with two directors — Director A and Director B. As on 31 March 2026, the company has an unsecured loan from Director A of Rs. 25 lakhs (with a valid written declaration) and a bank term loan of Rs. 40 lakhs. Both are non-deposit outstanding receipts. The company misses the 30 June 2026 deadline. An RoC compliance check flags the non-filing and a notice is issued on 15 September 2026 — meaning 77 days of continuing default after the due date.
Penalty calculation under Section 450 of the Companies Act, 2013:
| Entity | Base penalty | Daily penalty (77 days × Rs. 1,000) | Sub-total | Statutory cap | Amount payable |
|---|---|---|---|---|---|
| Company | Rs. 10,000 | Rs. 77,000 | Rs. 87,000 | Rs. 2,00,000 | Rs. 87,000 |
| Director A | Rs. 10,000 | Rs. 77,000 | Rs. 87,000 | Rs. 50,000 | Rs. 50,000 |
| Director B | Rs. 10,000 | Rs. 77,000 | Rs. 87,000 | Rs. 50,000 | Rs. 50,000 |
Total cash outflow from a 77-day delay: Rs. 1,87,000.
For context, a timely DPT-3 filing for this company would have cost a professional fee in the range of Rs. 5,000 to Rs. 12,000. The penalty represents a 15x to 37x multiple of what timely compliance would have cost.
This calculation also assumes the default stops at the date of the notice. If the company still does not file after the adjudication order, the daily meter continues (within the cap) until the form is actually submitted and approved. Separately, a non-filed DPT-3 that surfaces during a VC due diligence exercise or a bank credit appraisal can delay funding or reduce the loan sanction — costs that do not appear in any penalty table but are real.
Common Mistakes and Pitfalls to Avoid
1. Director loan with no written declaration
Many companies carry director loans in the books without the prescribed written declaration. When DPT-3 is filed years later, the certifying professional has no declaration to rely upon for the non-deposit classification. The amount then has to be reported as a deposit, potentially triggering credit-rating and DRR requirements retrospectively. Corrective action: Obtain fresh declarations for all existing director loans immediately and institutionalise the declaration as a pre-disbursement step.
2. Ignoring customer advances that have aged
An advance received against a service order that remains unfulfilled beyond the period agreed in the contract may no longer qualify for the non-deposit exclusion. Screen the "advance from customers" ledger specifically for credits older than 12 months before completing DPT-3. Any aged advance warrants a specific classification call before entry.
3. DPT-3 figures not reconciling with AOC-4
Your DPT-3 borrowings disclosure must match the borrowings note in the financial statements filed via Form AOC-4. The MCA V3 processing system cross-references these filings. A mismatch — even one caused by a post-audit adjustment — triggers an automatic query. Reconcile before you submit DPT-3; do not assume the auditor will catch it.
4. Certificates without UDIN
Since UDIN was made mandatory for attestation certificates, a certificate without a valid UDIN is non-compliant. RoC portals increasingly flag this. Verify that your auditor or practising professional has generated the UDIN on the relevant Institute's self-service portal and that the number is visible on the face of the certificate before uploading.
5. Expired or incompatible DSC
Class 3 DSCs typically have a two-year or three-year validity. A director or professional whose DSC expired on, say, 18 June 2026 cannot execute a form filed on 28 June 2026. Build a DSC expiry tracker into your compliance calendar with a 45-day advance-renewal alert.
6. Wrong return category selected
Filing Category 3 when you have actual deposits, or Category 2 when you have both deposits and non-deposit receipts, is a material error — not a formatting oversight. The certificate requirements are different for each category. Review the category selection with your CA before proceeding to the financial-particulars section.
7. Inter-corporate loan balances omitted
A loan received from a holding company, subsidiary, or associate is not a deposit, but it is an outstanding non-deposit receipt and must appear in DPT-3. These balances are frequently left out when the person filling the form focuses only on third-party lenders and overlooks related-party balances visible in the Notes to Accounts.
DPT-3's Links to Downstream Compliance
Connection to AOC-4 and the Directors' Report
The borrowing figures in DPT-3 must be consistent with Schedule III disclosures in the financial statements filed through Form AOC-4. The Directors' Report under Section 134 of the Companies Act, 2013 is increasingly expected to carry a statement of compliance with Sections 73 to 76 — and that statement is meaningless if DPT-3 has not been filed or carries figures inconsistent with the audited financials.
Investor due diligence
Private equity funds, venture capital investors, and strategic buyers routinely pull a company's MCA filing history as the opening step in commercial due diligence. A clean, unbroken DPT-3 filing history — correctly categorised, filed before 30 June every year, with financials that reconcile — signals that the finance function is under control. Missing or late filings have appeared in due diligence reports as governance risk factors, and in at least some documented instances have been used to support valuation haircut arguments.
Lender credit appraisals
Banks and NBFCs carrying out credit appraisals request MCA compliance certificates. DPT-3 defaults appear in inspection reports that lenders can access through the MCA system. A pattern of late DPT-3 filings has been cited in loan rejection notes as evidence of inattentive management — particularly in credit appraisals for mid-market term loans where governance quality influences pricing and tenor.
Trigger point for actual deposit compliance
If your company's borrowing pattern tips into actual public deposit territory — for instance, if you begin accepting fixed deposits from members without the required infrastructure — DPT-3 becomes the gateway to a significantly more intensive compliance obligation: mandatory credit rating by a SEBI-registered credit rating agency, deposit insurance, creation of the Deposit Repayment Reserve (DRR) equal to 20 per cent of deposits maturing in the following financial year, and separate filings in Form DPT-1 (advertisement for deposits) and Form DPT-2 (deposit trust deed). The DPT-3 filing history is the first document an investigator or insolvency professional will examine if deposit-compliance failures are alleged.
Key Takeaways
- Every company under the Companies Act, 2013 — except Government companies — must file Form DPT-3 by 30 June 2026 for its borrowing position as on 31 March 2026. This applies even if you have no actual deposits — a bank loan alone triggers the obligation.
- Select your return category carefully. Category 2 is for deposits only; Category 3 is for non-deposit outstanding receipts only; Category 4 is for both. A nil Category 3 filing is appropriate when you have neither deposits nor outstanding loans.
- The director-loan written declaration is a precondition, not an afterthought. A loan drawn without a prior written declaration may be reclassified as a deposit, pulling your company into credit-rating, DRR, and deposit-insurance requirements.
- Penalties accumulate fast. A 77-day delay on a two-director company costs nearly Rs. 1.87 lakh in statutory penalties — multiples of what timely filing would have cost. Both the company and each officer in default are separately assessed.
- Reconcile DPT-3 figures with your AOC-4 before submitting. Cross-form mismatches are the primary trigger for RoC queries and show-cause notices.
- All certificates must carry a valid UDIN, and all DSCs must be current. Run a DSC validity check at least 45 days before 30 June and build UDIN verification into your document checklist.
- Make DPT-3 readiness a standing item on the April or May board agenda. A 30-minute review of loan ledgers, director declarations, and the auditor briefing schedule in April is the difference between a clean June filing and a last-minute scramble — or worse, a missed deadline.
