A complete ROC compliance list with FY 2026-27 deadlines – annual, half-yearly, event-based and LLP filings, plus how the penalty math actually adds up.
ROC Compliance List & Deadlines for FY 2026-27
Every company registered under the Companies Act 2013 must manage two parallel compliance tracks in FY 2026-27: fixed-calendar filings anchored to your AGM date, and event-triggered filings that open a 15- to 30-day window the moment a corporate action occurs at the board or shareholder level. Miss either track, and the MCA V3 portal charges Rs. 100 per day per form with no upper cap — independent of any adjudication penalty the Registrar can impose under Sections 92 and 137 of the Companies Act. This guide maps every deadline, calculates what a miss actually costs, and gives you a tracker you can use today.
Why FY 2026-27 Raises the Stakes on ROC Compliance
The MCA V3 portal is now the sole live environment for all company and LLP filings. Several forms that previously had workarounds or tolerance for technical defects now require SRN-linked e-verification, current Digital Signature Certificate (DSC) registration, and compatible browser configurations. Last-minute technical failures during peak filing windows — particularly the September–November crunch — have become the most common cause of avoidable late-fee exposure.
The Centre for Processing Accelerated Corporate Exit (C-PACE) process has simultaneously made it faster for Registrars of Companies to strike off non-compliant entities. Under Section 248 of the Companies Act, a company that has not filed financial statements or annual returns for two consecutive financial years can be struck off without court intervention. Reinstatement requires an NCLT petition — a process that costs far more in legal fees and business disruption than any filing deadline you might have missed.
Finally, FY 2026-27 is fully governed by the flat Rs. 100-per-day additional fee structure. If your team is working off a pre-2023 penalty table that had slab-based fees, replace it immediately.
Month-by-Month MCA Filing Calendar for FY 2026-27
The calendar below assumes a standard private or public limited company with a 31 March financial year-end and an AGM held on the last permissible date of 30 September 2026. Adjust individual deadlines if your AGM is earlier — the countdown clocks start from the actual AGM date, not the latest permissible date.
April – May 2026
30 May 2026 — LLP Form 11 (Annual Return)
This is the LLP Annual Return for FY 2025-26, covering partner details, designated partner particulars, and total contribution as on 31 March 2026. Every registered LLP must file Form 11, including dormant LLPs with zero transactions. The late fee is Rs. 100 per day from 31 May 2026 with no cap. An LLP that lets this slip by even 90 days has locked in Rs. 9,000 in avoidable additional fees before any other filing is touched.
June 2026
30 June 2026 — DPT-3 (Return of Deposits)
DPT-3 covers FY 2025-26 and is filed on MCA V3. It is mandatory for every company that either accepted deposits from members or the public, or has outstanding amounts classified as exempt deposits under Rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules, 2014.
This second category is where private companies routinely go wrong. Exempt deposits include: loans from directors in their personal capacity (not as a shareholder), security deposits from business counterparties exceeding the prescribed threshold, and certain inter-corporate borrowings. If any such balance appears in your books as on 31 March 2026, DPT-3 is not optional.
What happens if you miss 30 June 2026: additional filing fee of Rs. 100 per day begins on 1 July 2026. The Registrar can also initiate inquiry proceedings for persistent non-filing, and lenders or investors conducting due diligence will flag a missing DPT-3 as a red flag on the company's compliance record.
July – September 2026
30 September 2026 — DIR-3 KYC for All DIN Holders
Every director, designated partner, or Key Managerial Personnel (KMP) who holds a Director Identification Number (DIN) must complete DIR-3 KYC by this date, for DINs issued or active up to 31 March 2026. The process is web-based for those whose mobile and email are already verified with MCA. Those updating contact details file the e-form version with a certifying professional.
The consequence of missing this deadline is automatic and immediate: the DIN is marked "Deactivated — non-filing of DIR-3 KYC" in the MCA system. A deactivated DIN means the holder cannot sign any e-form, cannot appear as an authorised signatory on any portal filing, and cannot be counted toward quorum for board resolutions — until reactivation by re-filing DIR-3 KYC with a Rs. 5,000 late reactivation fee.
This creates a cascading problem: if the authorised signatory's DIN is deactivated, no annual filing — AOC-4, MGT-7, or any other form — can be submitted until the DIN is live again. Three directors missing the DIR-3 KYC deadline costs the company Rs. 15,000 in reactivation fees before a single annual return is filed.
30 September 2026 — Annual General Meeting
Every company other than a One Person Company (OPC) must hold its AGM within six months of the close of the financial year — 30 September 2026 for FY 2025-26. An extension of up to three months can be granted by the Registrar on application under Section 96, but extensions are discretionary and should never be a planning assumption.
The AGM is not just a compliance checkbox — it is the trigger for four downstream filings. The moment the AGM is held, four deadline clocks begin simultaneously: AOC-4 (30 days), MGT-7 or MGT-7A (60 days), ADT-1 (15 days), and MGT-14 for any resolutions that are required to be filed.
October – November 2026
15 October 2026 — ADT-1 (Auditor Appointment)
ADT-1 must be filed within 15 days of the AGM at which an auditor is appointed or re-appointed for a fresh term. Following the Companies (Amendment) Act 2017, annual ratification of auditors was removed. ADT-1 is now required only on initial appointment and on reappointment at the end of a five-year block term. If your auditor's current term ends at the September 2026 AGM, you have until 15 October 2026 to file ADT-1 for the fresh appointment.
30 October 2026 — AOC-4 (Financial Statements)
AOC-4 must be filed within 30 days of the AGM. For an AGM on 30 September 2026, the hard deadline is 30 October 2026. The form carries the audited balance sheet, profit and loss account, auditor's report, directors' report, and all schedules adopted at the AGM. Listed companies and those above the XBRL threshold must attach XBRL-tagged financials. Small companies and OPCs are currently exempt from XBRL unless otherwise notified.
Missing AOC-4 exposes the company and every officer in default to: (1) Rs. 100 per day additional filing fee with no cap; and (2) adjudication under Section 137 — the company faces a penalty of Rs. 1,000 per day during which the failure continues, subject to a maximum of Rs. 10 lakh, while every officer in default faces imprisonment up to six months or a fine between Rs. 1 lakh and Rs. 5 lakh, or both.
31 October 2026 — MSME-1 (Outstanding Payments, April–September 2026)
Every company — regardless of size — that has outstanding payments to MSME-registered suppliers for more than 45 days as of 30 September 2026 must file MSME-1 by 31 October 2026. The corresponding half-year filing for October 2026 to March 2027 is due by 30 April 2027.
Do not assume you have no MSME vendors. A single disputed invoice held past 45 days with a vendor who is MSME-registered creates the filing obligation. Review your vendor master and outstanding payables ledger before each half-year end.
31 October 2026 — LLP Form 8 (Statement of Account and Solvency)
Form 8 must be filed within 30 days of the end of six months from the close of the financial year — 30 October 2026 for LLPs with a 31 March year-end. The form requires: a Statement of Solvency signed by all designated partners, a Statement of Assets and Liabilities, and a Statement of Income and Expenditure. If the LLP's turnover exceeds Rs. 40 lakh or its contribution exceeds Rs. 25 lakh, audited accounts and an auditor's report must be attached.
29 November 2026 — MGT-7 or MGT-7A (Annual Return)
The annual return must be filed within 60 days of the AGM. For an AGM on 30 September 2026, counting 60 days forward gives 29 November 2026. Small companies and OPCs file the abridged MGT-7A; all other companies file MGT-7, which requires certification by a Practising Company Secretary (PCS) unless the company qualifies as a small company.
Missing MGT-7 attracts additional portal fees of Rs. 100 per day, plus adjudication under Section 92(5): a company-level fine of Rs. 50,000 to Rs. 5 lakh, and personal liability for every officer in default — imprisonment up to six months or a fine between Rs. 50,000 and Rs. 5 lakh, or both.
The Event-Based Trigger-to-Form Map
These filings have no fixed calendar date. They activate the moment a corporate event occurs. Tracking the event — not just the form — is the compliance discipline.
| Event | Form | Window |
|---|---|---|
| Auditor appointed or reappointed at AGM | ADT-1 | 15 days from AGM |
| Any filable board or shareholder resolution passed | MGT-14 | 30 days from resolution date |
| Director appointed, resigned, or role changed | DIR-12 | 30 days from event date |
| Shares allotted (any class, any round) | PAS-3 | 30 days from allotment date |
| Charge created or modified | CHG-1 | 30 days from creation/modification |
| Charge satisfied | CHG-4 | 30 days from satisfaction date |
| BEN-1 (significant beneficial ownership declaration) received | BEN-2 | 30 days from receipt of BEN-1 |
| New company with share capital: commencement of business | INC-20A | 180 days from incorporation |
DIR-12 — the director-protection form: If a director's resignation is not filed in DIR-12 within 30 days of acceptance, the director's name remains active on the MCA system. The outgoing director continues to appear as a serving director on a company over whose actions they have zero control. Build a standing rule: the moment a resignation letter is accepted by the Board, the CS receives a copy the same day to begin preparing DIR-12.
CHG-1 — the banker-to-CS gap: Banks typically create a charge on your assets when a working capital facility is sanctioned. The 30-day window can expire before the treasury team realises it needs to be filed. Include a "notify the company secretary within 5 days of charge creation" clause in your internal facility drawdown checklist.
MGT-14 — not every resolution qualifies: Common filable resolutions include approval of financial statements, appointment of auditors, declaration of dividends, appointment of MD/CEO/CFO/CS, and resolutions requiring ordinary or special approval at a general meeting. Day-to-day operational board resolutions generally do not require MGT-14. When in doubt, verify against Section 117 of the Companies Act 2013.
LLP Compliance Summary: Form 8, Form 11, DIR-3 KYC
LLPs are governed by the Limited Liability Partnership Act, 2008, and their compliance calendar does not mirror companies exactly. The two filing deadlines — 30 May and 30 October — are fixed regardless of whether the LLP transacted business during the year.
Designated partners who hold a DIN are subject to the same DIR-3 KYC requirement as company directors: complete by 30 September 2026, failing which the DIN is deactivated and reactivation costs Rs. 5,000 per DIN. This deactivation directly prevents the signing of Form 8 and Form 11, creating a compounding problem if KYC is left to the last moment.
Worked Example: The True Cost of a Single Missed AGM Filing Cycle
Scenario: A five-year-old private limited company with two directors holds its AGM on 30 September 2026. A dispute with the outgoing auditor delays everything. The company files AOC-4 on 3 January 2027, MGT-7 on 10 February 2027, and separately discovers it also missed its DPT-3 (it had a director loan outstanding) and files that too on 3 January 2027.
AOC-4 late fee:
- Deadline: 30 October 2026 | Filing date: 3 January 2027
- Days late: 31 October (1 day) + November (30) + December (31) + 1–3 January (3) = 65 days
- Additional filing fee: Rs. 100 × 65 = Rs. 6,500
MGT-7 late fee:
- Deadline: 29 November 2026 | Filing date: 10 February 2027
- Days late: 30 November (1 day) + December (31) + January (31) + 1–10 February (10) = 73 days
- Additional filing fee: Rs. 100 × 73 = Rs. 7,300
DPT-3 late fee:
- Deadline: 30 June 2026 | Filing date: 3 January 2027
- Days late: July (31) + August (31) + September (30) + October (31) + November (30) + December (31) + 1–3 January (3) = 187 days
- Additional filing fee: Rs. 100 × 187 = Rs. 18,700
DIR-3 KYC — both directors missed the 30 September 2026 deadline:
- Reactivation fee per director: Rs. 5,000
- Total for 2 directors: Rs. 10,000
(Note: No annual filing could be submitted until both DINs were reactivated, meaning the AOC-4 filing date of 3 January was itself contingent on paying these reactivation fees first.)
Total MCA fee outflow from four missed or late filings:
| Form | Days Late | Additional Fee |
|---|---|---|
| DPT-3 | 187 | Rs. 18,700 |
| DIR-3 KYC (×2 directors) | — | Rs. 10,000 |
| AOC-4 | 65 | Rs. 6,500 |
| MGT-7 | 73 | Rs. 7,300 |
| Total | ||
| Rs. 42,500 |
This is the minimum unavoidable portal outflow — before any adjudication proceedings under Sections 92 or 137, before any professional fees for the remediation filing, and before any reputational damage with lenders or investors who reviewed the company's MCA master data during this period. The underlying cause was a single operational failure: not locking down a replacement auditor before the outgoing one raised a dispute.
Common Mistakes That Cause ROC Defaults
1. Treating the AGM as the finish line instead of the starting gun
Teams focus on holding the AGM on time and then relax for a week. The AGM simultaneously starts four countdown clocks — AOC-4 (30 days), MGT-7 (60 days), ADT-1 (15 days), and MGT-14 for resolutions. The week immediately after the AGM should be the most active compliance week of the year, not a rest period.
2. Assuming DPT-3 does not apply because "we don't take public deposits"
Private companies with director loans, shareholder advances, or business counterparty deposits that fall under exempt-deposit categories must file DPT-3 annually. The form is optional only for companies with a nil balance in both actual deposits and exempt-deposit categories. Pull your FY-end loan schedules before 15 June each year to make this determination before the rush.
3. Filing DIR-12 on the last day with a defective or expired DSC
DIR-12 requires a valid DSC from the relevant director (incoming or outgoing) and from the authorised signatory. If either DSC is expiring within 30 days of a director change, renew it before the corporate event. MCA V3 has strict DSC validation at upload. A failed submission on day 29 of the 30-day window leaves you with a one-day margin and no technical recourse.
4. Ignoring MSME-1 because "we pay our vendors promptly"
A single payment to an MSME-registered vendor delayed beyond 45 days — due to a disputed invoice, a bank holiday cluster, or a system processing lag — creates the filing obligation. Review your vendor master against the MSME/Udyam registration database and check your outstanding payables before 30 September and 31 March each year.
5. Treating LLP compliance as lower priority than company filings
LLP founders managing both a company and an LLP routinely file company forms on time and let LLP Form 11 and Form 8 accumulate late fees quietly. The Rs. 100-per-day fee applies equally to LLP forms. A six-month delay on Form 11 alone is Rs. 18,000 in fees — for a form that captures information the designated partners already have.
6. Underestimating Section 164(2) disqualification risk
Under Section 164(2) of the Companies Act 2013, a director is automatically disqualified from all board seats if the company in which they serve has failed to file financial statements or annual returns for any continuous period of three financial years. This disqualification applies across every directorship that person holds — not just the defaulting company. An independent director on five boards could lose all five directorships because one promoter-led company missed filings for three years. This is the most severe long-term consequence of treating ROC compliance as a low-priority clerical task.
How to Build a Working Compliance Tracker in Six Steps
A colour-coded spreadsheet without ownership and automation is a decoration, not a system. Here is a structure that works in practice:
Step 1 — Build a master event log with two columns: "Trigger Date" and "Filing Deadline." Every AGM, board meeting, share allotment, director change, charge creation, and BEN-1 receipt goes in as a trigger event. The deadline is auto-calculated using the trigger date plus the statutory window (15, 30, or 60 days, as applicable). This log is updated within 48 hours of every corporate event.
Step 2 — Assign one named owner per filing. Not "the CS team" — a specific individual. The company secretary, the CFO, or a named external consultant. Shared ownership produces gaps. Each person owns their list and is accountable to the board for it.
Step 3 — Set two automated reminders. First reminder: 15 days before the deadline, for document collection (board resolution, auditor's report, financial statements, DSC validity check). Second reminder: 3 days before the deadline, for upload to MCA V3, verification, and SRN confirmation.
Step 4 — Maintain an SRN master log. Every form filed on MCA V3 generates a Service Request Number. Log the SRN, filing date, form name, and the officer who authorised it. This log is your first-line defence during ROC inspections, statutory audits, and investor due diligence. Missing SRNs during a funding round have delayed closings.
Step 5 — Verify deadlines on MCA V3 after every government notification. The Ministry of Corporate Affairs has historically extended deadlines through circulars (as it did repeatedly during COVID-19 and in subsequent years). Do not rely on peer WhatsApp groups or social media for deadline changes. Check the official MCA V3 news section and the Ministry of Finance press releases directly.
Step 6 — Present compliance status at every quarterly board meeting. A one-page dashboard showing forms filed, forms due in the next 60 days, and any near-miss events converts compliance from a back-office clerical task into a board-level governance metric. It also creates an audit trail demonstrating that management applied diligent oversight — which matters in adjudication proceedings.
Key Takeaways
- The AGM on 30 September 2026 starts four simultaneous clocks — AOC-4 (due 30 October), MGT-7 (due 29 November), ADT-1 (due 15 October), and MGT-14 for filable resolutions; set all reminders on the day the AGM notice is dispatched, not the day the AGM is held.
- DPT-3 by 30 June 2026 is not optional for companies with director loans or exempt deposits — even a single rupee outstanding under a covered category triggers the filing obligation for FY 2025-26.
- DIR-3 KYC by 30 September 2026 applies to every DIN holder — company directors and LLP designated partners alike; a missed deadline deactivates the DIN, blocks all MCA filings for that signatory, and costs Rs. 5,000 per DIN to reactivate.
- The Rs. 100-per-day late fee has no cap — a 187-day delay on DPT-3 alone translates to Rs. 18,700 in additional fees before the Registrar even initiates adjudication under the Act.
- Event-based forms (DIR-12, PAS-3, CHG-1, MGT-14) have 15- to 30-day windows that cannot be extended — the CS must be notified of every corporate event within 48 hours of occurrence, not at month-end.
- LLP Form 11 is due 30 May 2026 and Form 8 by 30 October 2026 — both attract Rs. 100 per day in late fees and are mandatory even for dormant LLPs with nil transactions during the year.
- Three consecutive financial years of non-filing triggers automatic director disqualification under Section 164(2) across every board seat the director holds — making persistent ROC default one of the most expensive governance failures a founder or independent director can allow.
