Annual ROC Filings & Due Dates

Key facts

• AGM: within 6 months from the end of the financial year, so by 30 September for most companies. The first AGM is due within 9 months of the end of the first financial year. OPCs don't hold AGMs.
• AOC-4 (financial statements): within 30 days of the AGM. AOC-4 XBRL applies to listed companies and companies with paid-up capital of ₹5 crore or more or turnover of ₹100 crore or more.
• MGT-7 (annual return): within 60 days of the AGM. Small companies and OPCs file the shorter MGT-7A.
• ADT-1 (auditor appointment): within 15 days of the AGM at which the auditor is appointed. An auditor is appointed for a 5-year term.
• DPT-3 (return of deposits and outstanding loans not treated as deposits): by 30 June every year, for the position on 31 March.
• MSME-1 (dues to micro and small enterprises unpaid beyond 45 days): half-yearly, by 30 April for October–March and by 31 October for April–September.
• Late fee for most ROC forms: ₹100 per day of delay, with no upper cap, in addition to any penalty.
• Board meetings: at least 4 a year with a gap of no more than 120 days. Small companies, OPCs and dormant companies need only 2, one in each half of the year, at least 90 days apart.
• All MCA filings moved to the MCA V3 portal. Forms are web-based and need the DSC of a director and, where required, certification by a practising CA, CS or CMA.

Common questions

What is the due date for AOC-4 and MGT-7?

AOC-4 is due within 30 days of the AGM and MGT-7 (or MGT-7A) within 60 days. With the AGM on 30 September, the usual last dates are 29 October for AOC-4 and 28 November for MGT-7.

What is the late fee for ROC filing?

₹100 per day of delay for forms like AOC-4 and MGT-7, with no maximum. Separately, penalties apply: for not filing financial statements, ₹10,000 plus ₹100 a day up to ₹2 lakh for the company, and up to ₹50,000 for each officer in default.

When must the AGM be held?

Within 6 months from the end of the financial year, and in any case within 15 months of the last AGM. For a March year-end that means by 30 September. The first AGM can be held within 9 months of the end of the first financial year.

Who files MGT-7A?

Small companies and One Person Companies file the simpler MGT-7A annual return instead of MGT-7.

What is DPT-3?

An annual return of deposits and of money received that is not treated as a deposit (like loans from directors). It is due by 30 June for the position as on 31 March, with an auditor's certificate where required.

What is Form MSME-1?

A half-yearly return by companies that owe money to micro or small enterprises for more than 45 days. It shows the amount and reason for delay. Due by 30 April (for October–March) and 31 October (for April–September).

What is ADT-1?

The intimation of auditor appointment to the ROC, filed by the company within 15 days of the meeting that appointed the auditor. The auditor is normally appointed at the AGM for 5 years.

How many board meetings are required?

At least 4 a year with no more than 120 days between two meetings. Small companies, OPCs and dormant companies can hold just 2, one in each half of the calendar year, at least 90 days apart.

Sources

• Companies Act, 2013 (as amended)