Annual ROC Filings — AOC-4, MGT-7 & DPT-3 Deadlines
Quick Summary
Every Indian private limited company — even one with zero revenue — must file annual returns with the Registrar of Companies (ROC). The three flagship filings are Form AOC-4 (financial statements), Form MGT-7/7A (annual return), and Form DPT-3 (return of deposits). Missing these is the single most common cause of startup director disqualification under Section 164.
The Legal Breakdown / Why It Matters
The 3 Mandatory Annual ROC Filings:
| Form | What It Contains | Statutory Basis | Deadline |
|---|---|---|---|
| AOC-4 | Audited Balance Sheet, P&L, Auditor's Report, Board Report | Section 137, Companies Act | 30 days from AGM (by 29th Oct typically) |
| MGT-7 / 7A | Annual Return: shareholding, directors, changes | Section 92, Companies Act | 60 days from AGM (by 28th Nov typically) |
| DPT-3 | Return of deposits & exempted loans (incl. from directors) | Rule 16, Deposit Rules | 30th June every year |
Form MGT-7A is the simplified version for One Person Companies (OPC) and Small Companies.
Other Trigger-Based Filings
| Form | Trigger | Deadline |
|---|---|---|
| PAS-3 | Share allotment | 30 days from allotment |
| SH-7 | Increase in Authorized Capital | 30 days from resolution |
| MGT-14 | Special resolutions, certain board resolutions | 30 days from resolution |
| DIR-12 | Director appointment/cessation | 30 days from change |
| CHG-1 / CHG-4 | Creation / Satisfaction of Charge | 30 days |
| ADT-1 | Auditor appointment | 15 days from AGM |
Penalties for Late Filing
- AOC-4 & MGT-7: ₹100/day per default, no upper cap.
- DPT-3: ₹5,000 + ₹500/day continuing.
- Director Disqualification: If AOC-4 or MGT-7 is missed for 3 consecutive years, Section 164(2)(a) kicks in.
The Compliance Calendar
| Month | Filing Due |
|---|---|
| June 30 | DPT-3 (Return of Deposits) |
| September 30 | DIR-3 KYC / AGM deadline |
| October 29 | AOC-4 (30 days from AGM) |
| November 28 | MGT-7 / MGT-7A (60 days from AGM) |
How to Do It on Founding Legals
- Step 1: The Compliance Calendar shows all upcoming MCA deadlines, colour-coded by urgency.
- Step 2: For AOC-4, the platform integrates with your accounting software to pull audited financials. The Board Report and statements are auto-drafted.
- Step 3: For MGT-7, the platform auto-populates shareholding, directors, and change-events from your Cap Table.
- Step 4: For DPT-3, the platform identifies all exempted deposits (director loans, customer advances) and prepares the return.
- Step 5: Each filing is reviewed by a Company Secretary (CS) before submission to the MCA21 portal. You receive the Filed SRN copy within 24 hours.
Under Section 164(2)(a), if your company fails to file AOC-4 OR MGT-7 for any 3 consecutive financial years, every director is automatically disqualified for 5 years from all companies — and their DIN is deactivated. The MCA runs this check annually after 31st March. Once disqualified, recovery requires NCLT proceedings under Section 252.
Many founders procrastinate the AGM until November/December. But the AGM must be held within 6 months of FY end (i.e., by 30th September) under Section 96. Delaying the AGM by even a day cascades all downstream deadlines (AOC-4, MGT-7) and triggers their late-filing penalties. Block 25th–30th September on your calendar every year.