Revised DPT-3 Form for ED

Form DPT-3 is the annual return that companies file to disclose outstanding loans, advances and exempted deposits as on 31 March. Updated under MCA's V3 portal regime and aligned with recent Companies (Acceptance of Deposits) Rules amendments, DPT-3 for FY 2025-26 is due by 30 June 2026 and remains one of the most frequently mis-filed forms.

Who must file DPT-3

Every company, other than a government company, that has any outstanding loan or amount received which is not considered a deposit under Rule 2(1)(c) — i.e., exempted deposits — as on 31 March must file DPT-3. This includes private limited companies, public companies (listed and unlisted) and OPCs. Banking companies, NBFCs registered with RBI, housing finance companies registered with NHB and select notified entities are exempt.

What counts as exempted deposit

• Amount received from the central government, state government or any local authority.
• Amount received from foreign governments, foreign banks and certain notified bodies.
• Amount received as loan from any banking company or RBI-licensed institution.
• Amount received from a director or, in the case of a private company, from a relative of a director, against a written declaration of source.
• Inter-corporate loans received from any other company.
• Subscription money for shares, debentures or other securities, pending allotment within prescribed time.
• Trade advances received in the ordinary course of business not exceeding 365 days.
• Amount received from employees not exceeding annual salary in the nature of non-interest-bearing security deposit.

Categories of DPT-3 filing

1. Onetime return — historical position (already filed by most companies; relevant only for fresh issues).
2. Return of deposits — for companies that have accepted deposits under Section 73 / 76.
3. Return for exempted deposits — most private companies use this category.
4. Return for both deposits and exempted deposits — where both types are outstanding.

Information required in the form

DPT-3 requires the company to disclose its net worth as per latest audited financials, total outstanding deposits/exempted deposits as on 31 March, categorisation by lender type, auditor's certificate confirming the figures, and details of charges where security has been created. Errors in net worth, lender categorisation and CIN-PAN mapping are the most common rejection reasons on the V3 portal.

Penalties for non-filing

• Penalty on the company under Section 73(2)/76A — up to ₹1 crore.
• Penalty on every officer in default — up to ₹25 lakh and/or imprisonment up to seven years.
• Additional MCA filing fees for delay computed on the per-day slab.
• Reclassification risk — non-disclosure can lead to amounts being treated as deposits with serious consequences.

Practical filing steps

1. Reconcile the schedule of loans, advances and security deposits with the audited balance sheet.
2. Tag each balance against the relevant clause of Rule 2(1)(c).
3. Obtain the statutory auditor's certificate in the prescribed format.
4. Capture all charge details from the MCA Index of Charges to match the form data.
5. File DPT-3 on the MCA V3 portal on or before 30 June 2026.

What counts as deposit (and triggers Section 73/76)

Any amount received by a company that does not fall within the exempted-deposit list of Rule 2(1)(c) becomes a 'deposit' under Section 2(31) and triggers compliance with Sections 73 and 76 — circular resolution, members' approval, deposit insurance/charge creation, deposit repayment reserve account, and credit rating. Private companies cannot accept deposits from public; only from members up to specified limits. Breach can result in serious penalties and disqualification of directors.

Linkage with audit and AOC-4

• Statutory auditor's report under CARO 2020 specifically calls out deposit compliance and any contraventions.
• AOC-4 carries cross-references to deposits accepted, exempted and outstanding.
• Any inconsistency between DPT-3 and the financial statements triggers ROC inquiries and may invite Section 206 inspection.
• Companies with foreign loans must additionally reconcile DPT-3 disclosures with FC-GPR and ECB returns under FEMA.

Auditor coordination

DPT-3 requires an auditor certificate confirming the outstanding amounts disclosed. Coordinate with your statutory auditor early in May — they will need the loan register, sample agreements, banking confirmations and tagging working papers. A late auditor request in mid-June compresses their review and risks rejection. Where the company has multiple loan instruments — director loans, inter-corporate deposits, ECBs, customer advances — the auditor's certificate must cover each category with documented sub-totals matching the form.

Conclusion

DPT-3 is mechanical only if your loan register and audited balance sheet agree. Reconcile early in May, get the auditor's certificate signed, and file by mid-June so that any V3 portal hiccups can be resolved before the deadline. The penalty matrix for a missed DPT-3 is one of the steepest in the Companies Act — it is not the form to leave to the last day.