ROC Compliance in 2023-24 (FY 22-23)

ROC compliance for FY 2022-23 covered AOC-4 within 30 days of the AGM, MGT-7 within 60 days, ADT-1 within 15 days, DPT-3 by 30 June, MSME-1 half-yearly, and DIR-3 KYC by 30 September. The same structure carries into FY 2026-27 on the MCA V3 portal with stronger adjudication powers under Sections 454 and 454A. Defaults attract ₹100 per day per form with no cap, and three consecutive years of default in AOC-4 or MGT-7 lead to director disqualification under Section 164(2).

Mayank Wadhera

Published: 12 Jul 2023

Updated: 16 May 2026

3 min read

Although this article was originally written for FY 2022-23 filings, the structure of ROC compliance is built to carry forward. The same forms, the same triggers, and broadly the same penalty regime apply in FY 2026-27 with updated deadlines and tighter adjudication. This guide reframes the FY 2022-23 baseline against the current Companies Act regime so that companies revisiting historical filings, or planning forward, get a single reliable reference.

The Filings That Anchor a Year

AOC-4 – financial statements, within 30 days of the AGM.
MGT-7 / MGT-7A – annual return, within 60 days of the AGM.
ADT-1 – auditor appointment, within 15 days of the AGM.
DPT-3 – return of deposits, due 30 June.
MSME-1 – half-yearly return of MSME dues.
DIR-3 KYC – every director by 30 September.
BEN-2 – significant beneficial ownership filing as and when applicable.

What Changed Since FY 2022-23

Two big shifts. First, the MCA V3 portal is now the default for almost every filing, replacing the legacy MCA21 V2 interface. Web forms have replaced many e-forms, and DSC handling has been streamlined. Second, the adjudication regime under Sections 454 and 454A has matured – officers can directly impose monetary penalties for many defaults, without going through prosecution.

For companies that filed FY 2022-23 returns on the older V2 portal and are now revisiting historical compliance, the underlying data structure remains the same but the user experience differs significantly. Master data on V3 also captures more granular information on beneficial owners, charges, and director particulars.

Reviewing Historical Filings

Pull the master data of the company from MCA V3 to confirm last filed forms and their SRNs.
Compare against the year-by-year compliance calendar – is any AOC-4, MGT-7, or DPT-3 missing?
Check DIN status for every director who has held office; deactivated DINs need to be revived through DIR-3 KYC.
Identify any pending charge filings (CHG-1, CHG-4) that may have lapsed.
List event-based filings – PAS-3, DIR-12, MGT-14 – that should have been filed within 30 days of the trigger.

Penalty Math for Past Defaults

Late filing fees of ₹100 per day per form apply to most ROC defaults, with no upper cap. For a single AOC-4 or MGT-7 missed for two years, additional fees alone can run into ₹70,000–₹80,000 per form. Beyond that, adjudication officers may impose penalties under Section 137 (AOC-4), Section 92 (MGT-7), and Section 117 (MGT-14) depending on the specific default. Persistent default of three consecutive years in AOC-4 or MGT-7 triggers automatic director disqualification under Section 164(2).

Remediation Pathway

File pending DIR-3 KYC first to revive DIN status across all impacted directors.
File AOC-4 and MGT-7 in chronological order with the applicable additional fees.
Apply for Condonation of Delay before the Regional Director or NCLT under Section 460 where penalties are exceptionally heavy or technical defaults justify relief.
Where strike-off has happened, evaluate revival through NCLT under Section 252.
Document the entire remediation in a written file – this matters for due diligence and ROC inspections.

Conclusion

FY 2022-23 filings sit in the rearview mirror, but the discipline they demand has only become sharper in FY 2026-27. Whether you are cleaning up historical defaults or anchoring forward planning, treat the ROC calendar as a continuous spine – AOC-4 follows the AGM, MGT-7 follows AOC-4, DIR-3 KYC anchors September, DPT-3 anchors June. Companies that respect the rhythm rarely pay penalties; companies that ignore it almost always do.

Frequently Asked Questions

What were the key ROC filings for FY 2022-23?

Key ROC filings for FY 2022-23 included AOC-4 for financial statements within 30 days of the AGM, MGT-7 for annual return within 60 days, ADT-1 within 15 days, DPT-3 by 30 June 2023, MSME-1 half-yearly, and DIR-3 KYC by 30 September 2023. The same structure continues in FY 2026-27 with revised deadlines on the MCA V3 portal.

What is the penalty for past ROC defaults?

Past ROC defaults attract an additional fee of ₹100 per day per form, with no upper cap, plus potential adjudication penalties under Sections 137, 92, and 117 of the Companies Act, 2013. Persistent default in AOC-4 or MGT-7 for three consecutive financial years triggers automatic director disqualification under Section 164(2) and DIN deactivation.

Can past ROC defaults be regularised?

Yes. Past defaults can be regularised by first reviving DIN status through DIR-3 KYC, then filing each overdue form in chronological order with applicable additional fees. For heavy delays or technical defaults, an application for Condonation of Delay can be filed before the Regional Director or the NCLT under Section 460 of the Companies Act, 2013.

How is FY 2026-27 ROC compliance different from FY 2022-23?

The structure is largely the same – AOC-4, MGT-7, DPT-3, DIR-3 KYC, MSME-1, ADT-1 – but FY 2026-27 filings happen on the MCA V3 portal with web forms replacing many legacy e-forms, sharper master data capture, and stronger adjudication powers for ROC officers under Sections 454 and 454A of the Companies Act.