MCA compliance is not just a yearly checkbox. For companies in India, it directly affects governance credibility, director compliance status, lender confidence and penalty exposure. A missed ROC filing can lead to daily additional fees, adjudication proceedings, and in some cases serious operational complications. This practical guide explains the most important MCA filings for FY 2025-26, who needs to file them, when they are due, and what businesses should monitor in advance to avoid last-minute compliance failures.
Why MCA Compliance Matters in FY 2025-26
Corporate compliance under the Companies Act, 2013 is timeline-sensitive. Many ROC filings are linked to fixed statutory dates, while others depend on company events such as Board meetings, auditor appointments, cost audit reporting, beneficial ownership declarations and the annual general meeting.
For FY 2025-26, the compliance burden is not limited to annual filing forms like AOC-4 and MGT-7. Companies must also keep track of half-yearly, event-based and disclosure-driven forms such as MSME-1, PAS-6, DPT-3, BEN-2, CRA-2 and DIR-3 KYC. A missed filing can trigger both additional filing fees and separate statutory penalties under the Companies Act.
MCA Filing Calendar Summary for FY 2025-26
| Form | Applicability | Due Date / Trigger | Key Practical Point |
|---|---|---|---|
| MSME-1 | Specified companies with outstanding dues to micro or small enterprise suppliers beyond 45 days | 30 April and 31 October | Review vendor ageing carefully, not just payment ledger balances |
| PAS-6 | Unlisted public companies covered by Rule 9A for dematerialised securities | Within 60 days from 31 March and 30 September | Due dates generally fall around 30 May and 29 November |
| DPT-3 | Companies required to report deposits and/or outstanding receipts not treated as deposits, subject to rules | 30 June 2026 for information as on 31 March 2026 | Many companies wrongly skip this where only loans exist |
| DIR-3 KYC / DIR-3 KYC Web | DIN holders allotted DIN on or before 31 March 2026 | 30 September 2026 | Non-filing can deactivate DIN until reactivation filing is completed |
| CRA-2 | Companies required to appoint a cost auditor | Within 30 days of Board meeting or within 180 days from start of FY, whichever is earlier | For FY 2025-26, 180 days from 1 April 2025 falls in late September 2025 |
| MGT-14 | Resolutions and agreements covered under Section 117 and applicable rules | Within 30 days of passing the relevant resolution | Applicability depends on the nature of resolution and exemptions |
| CRA-4 | Companies covered by cost audit rules | Within 30 days from receipt of cost audit report | Do not confuse auditor report timeline with company filing timeline |
| ADT-1 | Company filing notice of auditor appointment | Within 15 days of the meeting in which auditor is appointed | Usually linked with AGM-based appointment or re-appointment |
| AOC-4 / AOC-4 XBRL / AOC-4 CFS | Companies filing financial statements | Within 30 days of AGM | For FY 2025-26, if AGM is on 30 September 2026, due date is 30 October 2026 |
| AOC-4 for OPC | One Person Company | Within 180 days from end of FY | For FY 2025-26, this generally falls on 27 September 2026 |
| MGT-7 / MGT-7A | Annual return of companies | Within 60 days of AGM | If AGM is on 30 September 2026, due date is 29 November 2026 |
| MGT-8 | Certification of annual return for prescribed companies | Filed along with annual return compliance cycle | Threshold-based certification requirement applies |
| BEN-2 | Company filing return regarding significant beneficial ownership declaration | Within 30 days of receiving BEN-1 | Ownership transparency failures can attract serious scrutiny |
Form-Wise MCA Compliance Guide
1. MSME-1: Half-Yearly Return for Outstanding MSME Dues
MSME-1 applies to specified companies that have outstanding payments to micro or small enterprise suppliers for more than 45 days from the date of acceptance or deemed acceptance of goods or services.
For the compliance cycle relevant to FY 2025-26, the important due dates are:
- 31 October 2025 for the period from April 2025 to September 2025
- 30 April 2026 for the period from October 2025 to March 2026
A common business example is where a company purchases materials in January 2026 from a registered micro or small enterprise and fails to clear the dues within 45 days. If the amount remains outstanding, the disclosure may become reportable in MSME-1 for the half-year ending March 2026.
2. PAS-6: Reconciliation of Share Capital Audit Report
PAS-6 is generally relevant to unlisted public companies required to issue securities in dematerialised form under Rule 9A of the Companies (Prospectus and Allotment of Securities) Rules, 2014. It is not a general form for all companies.
The return is to be filed within 60 days from the conclusion of each half-year:
- For half-year ended 30 September 2025, the due date generally falls on 29 November 2025
- For half-year ended 31 March 2026, the due date generally falls on 30 May 2026
This filing helps reconcile the company’s issued capital records with depository data and the register of members. If there is a mismatch, it can indicate governance weakness, clerical errors or more serious share capital control issues.
3. DPT-3: Return of Deposits and Particulars of Outstanding Receipts
DPT-3 is one of the most misunderstood MCA forms. Many companies assume that if they have not accepted public deposits, there is no filing exposure. That is not always correct. The form may still become relevant where the company has outstanding amounts that are not treated as deposits under the rules, such as certain loans or advances.
For information as on 31 March 2026, the annual filing due date is 30 June 2026.
A common real-world example is a director’s unsecured loan. Even if it is not treated as a deposit, the company still needs to examine whether reporting under DPT-3 is required.
4. DIR-3 KYC / DIR-3 KYC Web
Every DIN holder who has been allotted DIN on or before 31 March of a financial year must complete KYC compliance by 30 September of the immediately following financial year, subject to the mode applicable on the MCA portal.
For DIN holders covered up to 31 March 2026, the due date is 30 September 2026.
This is an area where outdated internet content causes mistakes. As per the MCA instruction kit currently available, DIR-3 KYC should still be monitored on an annual compliance basis for eligible DIN holders, not on a simple three-year cycle.
5. CRA-2: Intimation of Appointment of Cost Auditor
Companies required to appoint a cost auditor under the cost audit rules must file CRA-2:
- within 30 days of the Board meeting in which the appointment is made, or
- within 180 days of the commencement of the financial year,
whichever is earlier.
For FY 2025-26, where the financial year commenced on 1 April 2025, the outer 180-day timeline falls in late September 2025. If the Board approved the appointment on 15 May 2025, the 30-day limit would normally expire on 14 June 2025, which becomes the practical due date.
6. MGT-14: Filing of Certain Resolutions and Agreements
MGT-14 must be filed within 30 days for resolutions and agreements that fall within Section 117 and related provisions. This form is important, but its applicability must be checked resolution-wise. It is not correct to assume that every Board resolution automatically requires MGT-14.
Businesses should typically review MGT-14 exposure for matters such as borrowing powers, approval of certain reports and Board or shareholder decisions specifically covered by law. Also keep in mind that exemptions are available in some cases, particularly for certain private companies.
7. CRA-4: Filing of Cost Audit Report
After the cost auditor submits the cost audit report to the Board, the company must file CRA-4 within 30 days from receipt of that report.
If the cost auditor submits the report on the last permissible day, the company’s filing deadline shifts accordingly. This is why companies should not wait passively for the auditor. Internal follow-up is essential.
8. ADT-1: Notice of Auditor Appointment
Under Section 139, the company is required to file notice of auditor appointment with the Registrar within 15 days of the meeting in which the auditor is appointed.
Example: if the auditor is appointed or re-appointed in the AGM held on 30 September 2026, ADT-1 would generally be due by 15 October 2026.
9. AOC-4 / AOC-4 XBRL / AOC-4 CFS
AOC-4 is the core filing for financial statements. Under Section 137, a company must file its financial statements within 30 days of the date of the annual general meeting.
For FY 2025-26:
- if AGM is held on 30 September 2026, AOC-4 would generally be due on 30 October 2026
- for an OPC, the filing is within 180 days from closure of the financial year, which generally falls on 27 September 2026 for FY ending 31 March 2026
Businesses often focus only on additional filing fees, but that is only part of the risk. Separate statutory penalty provisions also exist under the Act.
10. MGT-7 / MGT-7A: Annual Return
Section 92 requires the annual return to be filed within 60 days from the date on which the AGM is held.
For FY 2025-26, if AGM is held on 30 September 2026:
- MGT-7 or MGT-7A due date would generally be 29 November 2026
MGT-7A is the abridged annual return generally used for OPCs and small companies. Other companies use MGT-7.
11. MGT-8: Certification of Annual Return
Certification in Form MGT-8 is required for annual returns of listed companies and certain other companies meeting prescribed thresholds. Based on the MCA rules in force, this typically applies where paid-up share capital is ten crore rupees or more, or turnover is fifty crore rupees or more.
This is not a separate annual return date by itself, but it becomes part of the annual return compliance process and should be planned before the MGT-7 filing window opens.
12. BEN-2: Significant Beneficial Ownership Reporting
BEN-2 is filed by the company within 30 days of receiving a declaration in Form BEN-1 from a significant beneficial owner.
This filing supports transparency of ultimate ownership and is especially important in group structures, layered holdings, nominee arrangements and closely-held companies with indirect control patterns.
Important Event-Based ROC Deadlines You Should Track Separately
Some MCA filings cannot be managed through a simple monthly calendar because their due dates depend on company events. For FY 2025-26, the following event-based timelines deserve special attention:
- MGT-14: 30 days from relevant resolution
- ADT-1: 15 days from meeting of appointment
- CRA-2: 30 days from Board meeting or 180 days from start of year, whichever earlier
- CRA-4: 30 days from receipt of cost audit report
- BEN-2: 30 days from BEN-1 receipt
- AOC-4 and MGT-7: tied to AGM date, not only financial year end
Late Fees, Penalties and Major Compliance Risks
1. Additional Filing Fees Can Escalate Quickly
For important annual forms such as AOC-4 and MGT-7, additional filing fees on the MCA portal are generally calculated at ₹100 per day of delay. A delay of 100 days can therefore create a filing cost of ₹10,000 per form, apart from any other legal exposure.
2. Statutory Penalties Are Separate from Additional Fees
Companies often treat MCA delay as only a portal fee issue. That is incomplete. The Companies Act also contains penalty provisions for non-filing or delayed filing under relevant sections such as Section 92 and Section 137.
3. DIN Deactivation Can Disrupt Governance
If directors fail DIR-3 KYC compliance, DIN status issues can interfere with signing and filing capability on the MCA portal. This can delay multiple other forms as well.
4. Funding, Due Diligence and Bank Reviews Can Be Affected
Compliance history matters in lender reviews, investor due diligence and transaction audits. A pattern of delayed ROC filings can weaken governance perception and create avoidable friction in funding discussions.
Smart Compliance Strategy for FY 2025-26
1. Build a Compliance Calendar with Exact Dates
Do not rely on broad statements such as “file after AGM” or “file in September”. Use exact calendar dates. For example, if your AGM is proposed on 30 September 2026, map AOC-4 for 30 October 2026 and MGT-7 for 29 November 2026 immediately.
2. Track Triggers, Not Just Due Dates
Many forms arise only after a trigger event. Maintain a tracker for Board meetings, auditor appointments, loans, MSME dues, SBO declarations and cost audit reporting events.
3. Review Ageing and Disclosure Data Monthly
MSME-1, DPT-3 and BEN-2 defaults usually happen because data was not reviewed early. Monthly monitoring is much safer than year-end reconstruction.
4. Keep Documentation Ready
- Board minutes and resolutions
- Auditor consent and appointment papers
- Loan declarations and supporting agreements
- MSME vendor declarations
- Beneficial ownership declarations
- Cost audit correspondence and reporting dates
5. Link ROC Compliance to Financial Risk Control
MCA compliance should be treated as a risk function, not just a secretarial calendar. The same discipline that protects ROC status also improves financing readiness and control over cash flow, governance and reporting.
Businesses that also want stronger documentation discipline around financial reporting and transaction visibility may find it useful to read our article on bank transaction limits, PAN requirements and reporting triggers in India.
Similarly, where compliance delays begin affecting working capital or regulatory response strategy, our guide on Rule 86A ITC blocking and legal remedies explains how delayed compliance action can create broader business pressure.
Related DN & CO. Articles
- Bank Transaction Limits 2026 in India: PAN Requirements, TDS on Cash Withdrawals, Section 269ST Rules & How to Avoid Income Tax Notices
- Rule 86A ITC Blocking Beyond 1 Year: Legal Position, High Court Judgments & Practical Relief Guide for Taxpayers
Official References
| Reference | What It Supports |
|---|---|
| Companies Act, 2013 | Sections 92, 137, 139 and overall annual filing framework |
| Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019 | MSME-1 applicability and half-yearly due dates |
| Instruction Kit for Form PAS-6 | PAS-6 filing window of 60 days from the conclusion of each half year |
| Instruction Kit for Form DPT-3 | DPT-3 annual filing requirement context |
| Instruction Kit for Form DIR-3 KYC | DIR-3 KYC due date and DIN holder compliance |
| Companies (Cost Records and Audit) Rules, 2014 | CRA-2 and CRA-4 timelines |
| Instruction Kit for Form MGT-14 | Resolution filing guidance under Section 117 |
| Instruction Kit for Form BEN-2 | SBO filing process and BEN-2 framework |
| Companies (Management and Administration) Amendment Rules, 2021 | MGT-8 threshold-based certification context |
Frequently Asked Questions
Is DPT-3 mandatory even when a company has not accepted public deposits?
It may still be relevant. Companies should review whether they have outstanding amounts that are not treated as deposits but are reportable under the rules. Do not assume automatic exemption.
What is the due date of AOC-4 for FY 2025-26?
It depends on the AGM date. If the AGM is held on 30 September 2026, AOC-4 is generally due on 30 October 2026.
What is the due date of MGT-7 for FY 2025-26?
It is within 60 days of the AGM. If the AGM is held on 30 September 2026, the due date is generally 29 November 2026.
Is DIR-3 KYC currently a once-in-three-years filing?
Based on the current MCA instruction kit, eligible DIN holders allotted DIN up to 31 March of a financial year are required to complete KYC by 30 September of the immediately next financial year. It should therefore be monitored annually unless MCA changes the framework.
Who files MGT-7A instead of MGT-7?
MGT-7A is the abridged annual return form for OPCs and small companies, while other applicable companies generally use MGT-7.
Can delayed MCA filings affect borrowing or investment discussions?
Yes. Lenders, investors, acquirers and professionals often review ROC compliance history during due diligence. Repeated filing defaults can weaken confidence in governance and financial discipline.
Final Takeaway
MCA compliance for FY 2025-26 should be handled as a structured governance process, not as a last-week filing exercise. The safest approach is to split compliance into three buckets: fixed-date filings, event-based filings and annual closing filings. Once this framework is built internally, the company can reduce both legal risk and operational disruption.
Strong ROC compliance does more than avoid late fees. It supports director readiness, smoother audits, cleaner due diligence and greater trust from lenders, investors and regulators. In a compliance-driven business environment, that discipline is a competitive advantage.
Disclaimer: This article is for general informational purposes only and is based on the Companies Act, 2013, MCA forms, rules and instruction kits publicly available as checked on 23 April 2026. Applicability and deadlines may vary depending on company type, exemptions, event dates, sector-specific rules and any later MCA notifications or relaxation circulars. Professional advice should be taken before acting on any filing position.