ROC Annual Filing

Every company incorporated under the Companies Act 2013 — whether private limited, public, OPC or Section 8 — must close its financial year with a structured cycle of statutory meetings, certifications and filings with the Ministry of Corporate Affairs (MCA) through the MCA21 portal (V3). The cycle is non-negotiable, time-bound, and increasingly automated by the MCA's straight-through processing engine — which means a single missed date does not just attract a late fee, it triggers an automatic 'non-compliant' tag on the master data, blocks event-based filings (charge creation, share allotment, director changes), and in extreme cases leads to strike-off under Section 248 and director disqualification under Section 164(2).

The 2026 ROC annual filing cycle hinges on three documents and three deadlines: the Annual General Meeting (AGM) under Section 96 within six months of the financial year-end (i.e., by 30 September for a 31 March year-end, with a one-time three-month extension permissible from the Registrar); e-form AOC-4 / AOC-4 XBRL for filing audited financial statements within 30 days of AGM; and e-form MGT-7 / MGT-7A (small companies and OPCs) for the annual return within 60 days of AGM. Layered on top: DPT-3 (deposits and amounts not regarded as deposits) by 30 June, MSME-1 half-yearly returns for MSME dues, BEN-2 for significant beneficial ownership, DIR-3 KYC per director by 30 September, and where Section 204 applies — secretarial audit and MR-3. Listed companies and large unlisted companies file in XBRL.

We run the entire ROC annual filing cycle as a single, time-tracked engagement — from AGM scheduling and resolutions through statement preparation, audit closure, e-form drafting, professional certification, MCA21 V3 submission, and master-data verification — so the company stays in 'active compliant' status throughout the year.

The Three Anchors — AGM, AOC-4, MGT-7

• AGM under Section 96:: First AGM within 9 months of first FY end; subsequent AGMs within 6 months of FY end and not more than 15 months apart. Notice 21 clear days, with explanatory statement under Section 102, attendance and proxy registers, and minutes within 30 days. AGM extension is granted by the Registrar for up to three months on application with cause.

• AOC-4 / AOC-4 XBRL — Within 30 Days of AGM:: Filing of audited Balance Sheet, P&L, Cash Flow (where applicable), Notes, Auditor's Report, Board's Report, CARO 2020 report, related-party disclosures, and CSR report (Section 135). XBRL mandatory for listed companies, companies with turnover ₹100 crore+, paid-up capital ₹5 crore+, all subsidiaries of listed companies, and any company that has filed XBRL in any prior year.

• MGT-7 / MGT-7A — Within 60 Days of AGM:: Annual return capturing share capital, debentures, members, directors, KMP, transfers, board meetings, AGM, and certifications. MGT-7A is the abbreviated return for OPCs and small companies. MGT-8 (CS certification) for companies with paid-up capital ₹10 crore+ or turnover ₹50 crore+.

The Surrounding Filings

DPT-3 — by 30 June: Return of deposits and amounts not regarded as deposits (loans from directors, shareholders, holding company, subsidiaries) — annual.
MSME-1 — Half-Yearly: Return of MSME dues outstanding for more than 45 days — by 30 April and 30 October.
BEN-2 — Event-Based: Filing of significant beneficial ownership declaration on identification of an SBO.
DIR-3 KYC — by 30 September: Per-director annual KYC; non-filing deactivates DIN with ₹5,000 reactivation fee.
ADT-1: Auditor appointment / re-appointment within 15 days of AGM.
MGT-14: Resolutions filed under Section 117 — board / shareholder resolutions on specified items within 30 days.

Secretarial Audit (Section 204) and MR-3

Mandatory for listed companies, public companies with paid-up capital ₹50 crore+ or turnover ₹250 crore+, and companies with outstanding loans / borrowings from public financial institutions ₹100 crore+. The Practising Company Secretary issues MR-3, annexed to the Board's Report and filed with AOC-4. We coordinate the audit alongside the financials so MR-3 is ready when AOC-4 is filed.

Penalties — and Why CFSS-Style Amnesty Is Not Reliable

Late AOC-4 / MGT-7: ₹100 per day per form, no upper cap. Continuing default beyond 270 days: strike-off proceedings under Section 248 and director disqualification under Section 164(2) for 5 years. The CFSS-2020 amnesty closed long ago; subsequent ad-hoc amnesty schemes are unpredictable. The reliable way to avoid the penalty is to file on time — which is the engagement we deliver.