Annual ROC Compliance Filing Assistance

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

AOC-4 (financial statements filing): within 30 days of AGM. For OPCs: within 180 days from the close of financial year (no AGM needed). MGT-7 (annual return for companies other than OPC/small): within 60 days of AGM. MGT-7A (annual return for OPC and small companies): within 60 days of AGM. Since AGM must be held by 30 September, AOC-4 is due by 30 October and MGT-7 by 29 November for most companies.

What is the additional fee for late ROC filing?

From 1 July 2022, MCA changed the fee structure: additional fee is ₹100 per day of delay for all e-forms (previously it was on a slab basis). For AOC-4 filed 30 days late: ₹3,000 additional fee. For 60 days late: ₹6,000. For 120 days late: ₹12,000. These fees are non-waivable and increase the longer you delay. MCA also publishes lists of defaulting companies — reputational risk in addition to financial penalty.

What happens if a company misses AGM?

Section 96 mandates every company (except OPC) to hold its AGM within 6 months from the end of the financial year (by 30 September). If AGM is missed: the company can apply to the RoC for a 3-month extension. If still no AGM: penalty for the company is ₹1 lakh and ₹5,000 per day of default (for officers in default). Non-holding of AGM for 2+ consecutive years can lead to strike-off proceedings by MCA.

What is DPT-3 and which companies must file it?

DPT-3 is a return of deposits and outstanding receipt of money/loans — filed annually by 30 June. Companies that have received any unsecured loans (from directors, shareholders, or others), debentures, or deposits must file DPT-3. Many promoters informally lend money to their company — these are "deposits" requiring DPT-3 disclosure. Failure to file attracts heavy penalties under Section 76A (₹1 crore or 2× deposit amount, whichever is lower).

Is annual ROC compliance required even for dormant companies?

Yes — all companies incorporated under the Companies Act must file annual returns (AOC-4 and MGT-7) regardless of whether any business was conducted. The only exception is a company that has obtained "dormant company" status (Section 455) — such companies file simplified Form MSC-3 annually. If you are not operating, it is better to either obtain dormant status or initiate voluntary winding up rather than accumulate mounting ROC compliance penalties.

What is the difference between MGT-7 and MGT-7A?

MGT-7 is the full annual return form for all companies except OPC and small companies. It includes detailed disclosures on shareholding pattern, changes in directors/KMPs, debenture holders, and other compliance matters. MGT-7A is a simplified annual return form for OPCs and small companies (paid-up capital ≤ ₹4 crore and turnover ≤ ₹40 crore) — fewer disclosures, simpler format.