Month-by-month ROC compliance calendar for Indian companies in FY 2026-27 with all annual, event-based filings and penalty risks.
ROC compliance is where most Indian startups bleed silent penalties. The MCA V3 portal now auto-checks for late filings and sends notices to directors directly. With director disqualifications under Section 164(2) hitting hard in FY 2026-27, founders must run a disciplined month-by-month ROC calendar. Use this as a finance and CS pinned reference.
Annual Filings
- MGT-7: Annual Return within 60 days of AGM.
- AOC-4: Financial Statements within 30 days of AGM.
- DIR-3 KYC: by 30 September annually for all directors.
- MSME Form 1: half-yearly by 30 April and 31 October if dues to MSMEs outstanding beyond 45 days.
- DPT-3: by 30 June annually for outstanding loans not considered deposits.
Event-Based Filings
- PAS-3: Return of Allotment within 30 days of allotment of shares.
- MGT-14: within 30 days of special resolutions on specified matters.
- DIR-12: within 30 days of director appointment, resignation or changes.
- SH-7: within 30 days of alteration of share capital.
- INC-22: within 30 days of change of registered office.
- CHG-1 and CHG-4: for creation, modification and satisfaction of charges within prescribed time.
- BEN-2: within 30 days of receiving Form BEN-1 for significant beneficial owners.
Suggested Monthly Compliance Rhythm
- April: Plan AGM, draft financial statements, audit kickoff.
- May: Hold board meeting to approve audited financials, fix AGM date, file DPT-3.
- June: Hold AGM (if FY ends March), file AOC-4 within 30 days, MGT-7 within 60 days, file ITR-6 if not subject to tax audit.
- July: File AOC-4 and MGT-7 if AGM held in June, FLA return by 15 July, complete ITRs.
- August: Catch up on event-based filings, file Form 11 for LLPs by 30 May (LLP).
- September: DIR-3 KYC by 30 September.
- October: ITR-6 filing where tax audit applies by 31 October, half-yearly MSME Form 1 by 31 October, GSTR-9 and 9C filings begin.
- November-December: Hold the second board meeting if not yet, plan financial year-end activities.
- January-March: Advance tax compliance, prepare for FY-end, plan capital structure decisions.
Penalties and Director Risk
- Late filing of MGT-7 or AOC-4 attracts ₹100 per day with no upper cap.
- Three consecutive years of non-filing leads to director disqualification under Section 164(2) for 5 years.
- ROC may strike off the company under Section 248 suo moto for non-filing.
- Each form has its own additional fee schedule under Section 403 from 2018 amendments.
Automating the Calendar
Tools like RazorpayX, Vakilsearch, Zoho People or even a shared Google Calendar with assigned owners drastically reduce the failure rate. Pair this with a monthly compliance review where the CS, CA and CFO walk through every upcoming filing in the following 60 days. Catch issues early when they are cheap to fix.
Conclusion
ROC compliance is rhythmic, not heroic. Build a calendar, assign owners, automate reminders, run monthly reviews, and the entire annual cycle becomes predictable. The discipline keeps director DIN clean, protects the cap table integrity and avoids the silent damage that bleeds equity value over years.
