ROC Compliance Calendar for Oct 2021

ROC Compliance Calendar for Oct 2021

Updated for FY 2026-27 | MCA V3 Portal | Companies Act 2013 & LLP Act 2008

For FY 2026-27, every registered Indian company and LLP must navigate a year-round filing schedule on the MCA V3 portal — covering AGM-linked returns, half-yearly compliance forms, director KYC, and event-triggered disclosures. Miss a due date and you face Rs. 100 per day in additional fees for annual filings under Section 403, graded multiples of up to 12× the base fee for other forms, and LLP Act penalties of Rs. 100 per day per entity and per designated partner with no upper cap. This guide gives you the exact due dates, the penalty arithmetic, and a step-by-step build plan so you never arrive at a deadline unprepared.

Why a Compliance Calendar Is Non-Negotiable in FY 2026-27

The regulatory landscape has shifted from reactive to predictive. Under the old MCA21 portal, overdue filings sometimes slipped through manual gaps. With MCA V3 fully operational, the system cross-references each company's filing history against its master data in real time. Lenders running a due diligence check, investors verifying company status, and rating agencies pulling bureau reports now see a live "Active / Strike-off Pending / Disqualified" flag alongside registration details.

Three structural changes make this especially urgent in FY 2026-27:

• Automatic strike-off under Section 248 of the Companies Act, 2013 is triggered when a company has not filed its annual return or financial statements for two consecutive financial years. Once the Registrar issues a Section 248 notice, the company has 30 days to respond — failing which, the name is struck off the register.
• Director disqualification under Section 164(2) operates automatically when a director serves on a company that has defaulted in filing annual returns or financial statements for three consecutive years. The disqualification bars that director from holding any directorship in any company for five years, and the MCA portal lists the disqualification publicly.
• Cross-database integration means MCA V3 now shares data with the Income Tax Department (PAN/AIS), GSTN, and the MSME Udyam registry. An "Active Compliant" status on MCA is increasingly a prerequisite for smooth GST amendments, bank credit, and government-tender eligibility.

The cheapest form of insurance a company can buy is a filing calendar reviewed quarterly at the board level.

Annual ROC Filings for Companies: The Complete FY 2026-27 Calendar

The date anchor for most annual company filings is the Annual General Meeting (AGM). Under Section 96(1) of the Companies Act, 2013, every company must hold its AGM by 30 September of each year (first AGM has different rules). Using 30 September 2026 as the AGM date, here is the full due-date map:

AOC-4: What "30 Days After AGM" Actually Means

The 30-day clock under Section 137(1) starts from the date the AGM concludes — not the date of the board meeting that approved the accounts. Financial statements filed must be those adopted at the AGM, not the draft circulated with the notice. If the AGM is adjourned (common when accounts are contested by members), the 30-day clock restarts from the date the adjourned meeting is concluded.

Common failure mode: Companies upload the board-approved draft before the AGM has taken place. MCA V3 does not automatically reject this, but a Registrar scrutiny will flag the inconsistency between the AGM date in the form and the system timestamp. Always file AOC-4 after the AGM resolution is passed and the accounts are formally adopted.

DPT-3: The Form Every Company Must File, Not Just Deposit-Taking Ones

DPT-3 is a return under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. The widespread misconception is that it only applies to companies that accept public deposits. It does not. Every company that holds any amount falling under the "exempt deposit" categories in Rule 2(1)(c) — including director loans, inter-corporate borrowings, advance from customers held beyond 365 days, and security deposits from employees — must file DPT-3 by 30 June each year.

For FY 2026-27, the due date for DPT-3 is 30 June 2027. A private limited company that has taken a Rs. 20 lakh unsecured loan from its director must disclose this in DPT-3. Filing a nil DPT-3 when the balance sheet shows director loans is a false declaration — a more serious default than simply filing late.

MSME-1: Two Deadlines, Two Data Points

MSME-1 applies to companies as specified by the Ministry of Corporate Affairs. The form captures outstanding dues to MSME-registered suppliers that have remained unpaid for more than 45 days. There are two mandatory filing windows per financial year:

• April–September 2026 period: outstanding as at 30 September 2026, filed by 31 October 2026
• October 2026–March 2027 period: outstanding as at 31 March 2027, filed by 30 April 2027

Before preparing the form, verify each supplier's Udyam Registration Number (UAN) on the Udyam portal. MCA V3 validates UANs during form submission. A supplier listed as MSME in your books but whose registration has lapsed will cause a validation error.

Annual Filings for LLPs: Form 11, Form 8, and DIR-3 KYC

LLPs operate under the Limited Liability Partnership Act, 2008 and the LLP Rules, 2009. The annual filing calendar is leaner but the per-day penalty is sharper and applies simultaneously to the LLP and each designated partner.

Form 8: Accounts With a Solvency Declaration

Form 8 carries the LLP's balance sheet, profit and loss account, and a declaration by designated partners that the LLP is solvent — meaning it is able to pay its debts as they fall due in the normal course of business. For LLPs with a turnover exceeding Rs. 40 lakh or capital contribution exceeding Rs. 25 lakh, the accounts must be audited by a Chartered Accountant before Form 8 is filed.

Form 8 requires certification by a CA and signature by at least two designated partners using valid DSCs. The most common delay source is late account finalisation — designated partners waiting for tax working before signing off. The statutory due date is 30 October; accounts should be ready by mid-September.

DIR-3 KYC: Annual Renewal for Every DIN Holder

Every individual who holds a Director Identification Number (DIN) — whether or not currently active — must complete DIR-3 KYC by 30 September each year. The form links the DIN to the holder's PAN, Aadhaar, mobile number, and email OTP verification. For FY 2026-27, the due date is 30 September 2026.

A DIN that misses the KYC deadline is marked "Deactivated" by the Registrar. The only way to reactivate it is to file DIR-3 KYC with a late fee of Rs. 5,000. Since MCA forms require at least one active DIN for digital signing, a deactivated DIN blocks all subsequent MCA filings for that entity — creating a cascade of delayed forms, each accumulating its own additional fees.

Event-Based MCA Forms: The Filings That Catch Founders Off Guard

Annual forms appear on every reminder list. Event-based forms do not — yet they carry the same penalty consequences and, in the case of charge registration, can affect the legal priority of a lender's security interest.

Forms With a 15-Day Window

• ADT-1: Auditor appointment following AGM. File within 15 days of the AGM under Section 139(1).
• INC-20A: Declaration of commencement of business. A company incorporated after 2 November 2018 must file this before commencing any business or exercising borrowing powers. It is a condition precedent, not an annual form — and operating without filing it is a Section 10A default.

Forms With a 30-Day Window

• DIR-12: Appointment, resignation, or cessation of directors and KMP. File within 30 days of the board resolution or the effective date of change. Under Rule 15 of the Companies (Appointment and Qualification of Directors) Rules, 2014, this clock runs from the date of appointment or the date of receipt of the director's resignation letter.
• MGT-14: Board and shareholder resolutions required to be filed under Section 117. This includes resolutions to borrow beyond paid-up capital (Section 179(3)(d)), special resolutions passed at general meetings, and agreements under Sections 117(3). File within 30 days of passing the resolution.
• PAS-3: Return of allotment of securities. File within 30 days of the date of allotment under Rule 12 of the Companies (Prospectus and Allotment of Securities) Rules, 2014. This applies to every allotment — angel round, ESOP exercise, rights issue, preference share issuance.
• SH-7: Alteration of authorised share capital. File within 30 days of the general meeting resolution approving the increase.
• CHG-1: Creation or modification of a charge. File within 30 days of the date of creation. Late filing is permissible with higher fees within the extended period as prescribed; beyond that, a condonation petition is required.
• INC-22: Change of registered office within the same city or town. File within 30 days of the board resolution authorising the change.
• BEN-2: Significant Beneficial Ownership (SBO) return under Section 90. File within 30 days of receiving a BEN-1 declaration from the SBO.

What consistently goes wrong: Founders treat post-round secretarial work as administrative backlog. An ESOP grant happens in April, the PAS-3 window expires in May, and the form is eventually filed in October with five months of additional fees. The fix is a standing instruction: any board resolution that triggers an MCA form is logged in the compliance tracker on the same day the resolution is passed, with the due date calculated immediately.

Worked Example: The True Cost of Two Missed Deadlines

Scenario A: LLP Missing Form 8

A three-partner LLP with turnover of Rs. 85 lakh misses Form 8 for FY 2025-26.

• Form 8 due: 30 October 2026
• Form 8 actually filed: 17 May 2027
• Delay: 199 days

Penalty under Section 34(3) of the LLP Act, 2008 (Rs. 100 per day):

This is the penalty for one form, on top of normal filing fees and CA certification charges. If Form 11 (due 30 May 2027) is also filed 200 days late, the same structure applies — adding another Rs. 80,000 in total penalties.

Scenario B: Private Limited Company Missing AOC-4 and MGT-7

A private limited company with Rs. 10 lakh authorised capital holds its AGM on 30 September 2026. Both AOC-4 (due 30 October 2026) and MGT-7A (due 29 November 2026) are filed on 17 May 2027.

• AOC-4 delay: 199 days
• MGT-7A delay: 169 days

Under Section 403 of the Companies Act (as amended by the Companies Amendment Act, 2019), annual return and financial statements attract an additional fee of Rs. 100 per day of delay beyond the due date:

This is the fee to merely file the forms. Separately, Section 137(3) adjudication can impose a penalty of Rs. 10,000 on the company and Rs. 10,000 per officer in default (MD/CFO/responsible director), continuing at Rs. 100 per day, subject to a maximum of Rs. 2,00,000 for the company and Rs. 50,000 per officer. These adjudication penalties are at the Registrar's discretion but are increasingly being levied as MCA shifts to system-driven compliance monitoring.

How to Build a Working ROC Compliance Calendar

A compliance calendar only works if it generates action before a deadline, not after. Here is a practical build sequence for FY 2026-27:

1. List every form applicable to your entity type. Use the tables in this article as your starting inventory. Add event-based forms only when the triggering event occurs.
2. Anchor to the AGM date. Fix your AGM date — no later than 30 September 2026 — and back-calculate all form due dates from there. Most annual forms flow from this single anchor.
3. Assign a named owner and named backup for each form. Ownership without accountability does not produce results. The responsible person must hold an active DIN or be the entity's authorised representative.
4. Set three-layer reminders. For every due date: a 30-day advance alert, a 7-day alert, and a 24-hour alert. Automate these in calendar software — do not rely on memory or a spreadsheet that is checked quarterly.
5. Track DSC validity as a separate column. An expired Digital Signature Certificate on filing day causes an immediate delay. Add a DSC expiry date column and set a renewal reminder 60 days before expiry.
6. Review the calendar at every quarterly board meeting. Section 173 requires at least four board meetings per calendar year with no gap exceeding 120 days between consecutive meetings. Plan these in April, July, October, and January. Build a compliance status review into the standing agenda for each meeting.
7. Log event-based triggers in real time. The moment a board passes a resolution that triggers an MCA form — allotment of shares, borrowing approval, director change — log the form and its due date in the compliance tracker on the same day.

Common Pitfalls and How to Fix Them

Pitfall 1: Filing AOC-4 Before the AGM Is Concluded

MCA V3 does not always catch this at submission stage, but a Registrar scrutiny will. Financial statements filed must be those adopted at the AGM, not the board-approved draft. File AOC-4 only after the AGM resolution is passed and the minutes capture the adoption.

Fix: Include the AGM resolution number and date in the AOC-4 checklist. No resolution number = do not submit.

Pitfall 2: Treating DPT-3 as Applicable Only to Deposit-Taking Companies

Every company with any director loan, inter-corporate borrowing, or customer advance outstanding at 31 March must file DPT-3 by 30 June. A nil DPT-3 filed against a balance sheet that shows director loans is a false declaration under Rule 16.

Fix: Cross-reference the DPT-3 data against the notes to accounts for unsecured loans and other financial liabilities before filing.

Pitfall 3: Overlooking DIR-3 KYC for Non-Executive and Nominee Directors

Founders complete KYC for working directors but miss independent or investor-nominee directors. Every DIN holder must complete annual KYC regardless of role.

Fix: Pull the full list of DIN holders from the company's Register of Directors (Section 170) at the start of September each year and confirm KYC completion for each name.

Pitfall 4: Miscalculating MSME-1 Due Dates

The April–September half-year return is due by 31 October, not 30 November. Companies that file in November for the April–September period are already one month in default.

Fix: Set two separate calendar events on 1 October and 1 April each year titled "Begin MSME-1 preparation" so you have four weeks of run-up to both deadlines.

Pitfall 5: Missing MGT-14 for Internal Borrowing Resolutions

Section 179(3) read with Section 117(1) requires MGT-14 to be filed within 30 days for board resolutions that approve borrowing beyond paid-up capital plus free reserves. A working capital loan approved at a board meeting on 1 July 2026 means MGT-14 is due by 31 July 2026 — a deadline that many companies discover only during the annual secretarial audit, months later.

Fix: Keep a two-column log alongside the board meeting register: (a) resolution type and (b) MCA form triggered, if any. This is updated the day minutes are circulated for approval.

MCA V3 Portal Tips: Filing Without Rejections

The MCA V3 portal at unknown node uses single sign-on with DSC-based two-factor authentication and auto-validates form data against multiple government databases in real time. The most common rejection reasons — and their fixes:

• PAN mismatch: The PAN entered in the form must exactly match the PAN against the company or director in MCA master data. Even a transposition error causes rejection. Verify PAN linkage in the MCA profile before initiating any form.
• DIN not linked to PAN: If a director's DIN is not linked to their PAN in the MCA database (a common issue for older DINs), form-level validation fails. Resolve this through a DIR-3 or DIR-3 KYC update before attempting the linked form.
• Bank account verification pending: Forms requiring bank account details (such as INC-20A) may reject if the account has not been pre-verified with the MCA system. Complete bank account linkage at the beginning of the financial year, not at the time of filing.
• Portal congestion: MCA V3 experiences significantly higher load in the 72 hours before any major deadline. A submission attempted at 11:55 PM on the due date that times out is a missed filing. Start every filing at least two weeks before the statutory due date.
• DSC not registered on MCA portal: A new or renewed DSC must be registered on the MCA portal before it can be used for form signing. Complete this registration immediately upon receiving the DSC — not on the day you plan to file.

Statutory Registers and Board Meeting Discipline

Filing forms on the MCA portal is the visible layer of compliance. Statutory registers are the work that happens off the portal but surfaces during investor due diligence, lender verification, and Registrar inspections.

Registers Every Company Must Maintain

• Register of Members — Section 88, with allotment dates, folio numbers, and transfer history
• Register of Directors and KMP — Section 170, updated within 30 days of any change
• Register of Charges — Section 85, with complete particulars of each charge and satisfaction date
• Register of Contracts — Section 189, for every contract in which a director has a direct or indirect interest
• Register of Loans and Investments — Section 186, for every inter-corporate loan, guarantee, or investment
• Register of Significant Beneficial Owners — Section 90, updated upon receipt of each BEN-1 declaration

These registers must be maintained at the registered office and produced for inspection within 24 hours of a Registrar's notice under Section 206.

Board Meeting Frequency and the 120-Day Rule

Section 173(1) mandates at least four board meetings per calendar year with no gap exceeding 120 days between consecutive meetings. Minutes must be entered in the Minutes Book and signed by the Chairman of the meeting or the Chairman of the next meeting within 30 days of the meeting.

Plan your four meetings at the start of each year — April, July, October, and January is a practical cadence that aligns with quarter-end financial reviews and keeps the 120-day gap requirement safely met. Section 173 compliance also validates every resolution passed at the meeting; resolutions passed at inquorate or irregularly convened meetings are vulnerable to challenge.

For listed entities and prescribed classes of companies, a Secretarial Audit under Section 204 is mandatory, and the secretarial audit report (MR-3) is annexed to the Board's Report. Even for non-mandatory companies, an annual internal secretarial compliance review by a Practising Company Secretary is a sound discipline that identifies gaps before a Registrar scrutiny does.

Key Takeaways

• AOC-4 is due 30 days after the AGM (30 October 2026 if AGM is on 30 September 2026); MGT-7 / MGT-7A is due 60 days after the AGM (29 November 2026). Both attract Rs. 100 per day in additional fees under Section 403 as amended by the Companies Amendment Act, 2019.
• DPT-3 is due 30 June 2027 for FY 2026-27 and applies to all companies holding any exempt-deposit category — including director loans. Filing nil DPT-3 when the balance sheet shows unsecured director loans is a false declaration.
• MSME-1 has two firm due dates: 31 October 2026 for the April–September half-year, and 30 April 2027 for the October–March half-year. Both require UAN validation against the Udyam registry at filing.
• DIR-3 KYC is due 30 September 2026 for every DIN holder regardless of whether the director is active. A deactivated DIN (Rs. 5,000 to reactivate) blocks all MCA filings for the entity and triggers cascading delays.
• LLP Form 8 due 30 October carries a penalty of Rs. 100 per day on the LLP and Rs. 100 per day on each designated partner separately under Section 34(3) of the LLP Act — a three-partner LLP filing 200 days late pays Rs. 80,000 in penalties alone, before filing fees.
• Event-based forms — PAS-3 (30 days), MGT-14 (30 days), DIR-12 (30 days), CHG-1 (30 days), ADT-1 (15 days) — begin their clock from the triggering event. Log each form in the compliance tracker on the day the board resolution is passed.
• MCA V3 technical failures (PAN mismatch, expired DSC, portal congestion) are the most common cause of last-day missed filings. Start every filing at least two calendar weeks before the statutory due date and verify PAN, DIN, and DSC status before initiating any form.