AOC-4, MGT-7, ADT-1, CRA-4, MSME-1 and more — what is due, what has been relaxed, and how to plan the rest of the season
The annual ROC filing season is the final step in closing a company’s financial year under the Companies Act, 2013. Once the accounts are audited and adopted at the AGM, the company must file its financial statements and annual return with the Registrar of Companies, along with a few related forms.
This year there is welcome news. On 24 October 2026, the Ministry of Corporate Affairs (MCA) issued General Circular No. 05/2026, allowing companies to file their FY 2025-26 financial statements and annual returns without additional fees for a longer period. The relief follows representations from professional bodies about disruptions on the MCA-21 V3 portal.
This guide sets out the revised dates, the forms the relief does (and does not) cover, and a practical plan to finish the season comfortably.
1. The headline: MCA General Circular 05/2026
The circular relaxes additional fees for the following e-forms relating to FY 2025-26:
| Form | Purpose | Statutory due date* | Fee-free up to |
|---|---|---|---|
| AOC-4, AOC-4 (CFS), AOC-4 (XBRL) | Financial statements | 30 October 2026 | 31 December 2026 |
| AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | Financial statements of Ind AS NBFCs | 30 October 2026 | 31 December 2026 |
| AOC-4 for One Person Company | Financial statements | 27 September 2026 | 31 December 2026 |
| MGT-7 | Annual return | 29 November 2026 | 31 January 2027 |
| MGT-7A | Annual return (OPC / small company) | 29 November 2026 | 31 January 2027 |
*Assuming the AGM is held on 30 September 2026. For an OPC, AOC-4 is due within 180 days from the close of the financial year.
In short
File AOC-4 (any variant) by 31 December 2026 and MGT-7 / MGT-7A by 31 January 2027, and only the normal filing fee is payable.
2. What the relaxation does not cover
The circular is a relief from additional fees on specified forms. It is not a general extension of every Companies Act timeline, so a few points deserve attention:
- No extension of the AGM deadline. The time to hold the AGM under Section 96 (30 September 2026 for most companies) is unchanged. Companies that have not held their AGM remain in default unless the Registrar granted an extension.
- Other forms keep their regular dates. ADT-1, MGT-14, CRA-4, MSME-1, DIR-12 and other event-based forms are not included in the circular.
- Normal fees remain payable. Only the additional fee is waived.
- Missing the extended date costs more than you may expect. A filing made after the relaxed date attracts additional fees counted from the original statutory due date, not from 31 December or 31 January.
- No refund mechanism. The circular does not address additional fees already paid before 24 October 2026.
- Penal provisions are untouched. The relief covers additional fees only; it does not condone defaults such as a delayed AGM.
How the additional fee works if you miss the window
Under the Companies (Registration Offices and Fees) Rules, 2014, the additional fee for AOC-4 and MGT-7 is ₹100 per day of delay. Here is how paragraph 4 of the circular plays out for a company whose AGM was held on 30 September 2026:
| Form | Filed on | Delay counted from | Additional fee |
|---|---|---|---|
| AOC-4 | 28 December 2026 | Not applicable (within relief) | Nil |
| AOC-4 | 10 January 2027 | 30 October 2026 (72 days) | ₹7,200 |
| MGT-7 | 25 January 2027 | Not applicable (within relief) | Nil |
| MGT-7 | 5 February 2027 | 29 November 2026 (68 days) | ₹6,800 |
The lesson is simple: filing even one day after the relaxed date reopens the full count from the original due date. Treat 31 December and 31 January as firm.
3. Complete ROC calendar for FY 2025-26
The table below brings together the annual Companies Act filings for a company with a 31 March 2026 year end and an AGM on 30 September 2026.
| Form | What it covers | Time limit | Date for FY 2025-26 |
|---|---|---|---|
| AGM | Adoption of audited accounts | Within 6 months of year end | 30 September 2026 (not extended) |
| ADT-1 | Auditor appointment / re-appointment | Within 15 days of the AGM | Mid-October 2026 (not covered by relief) |
| AOC-4 (all variants) | Financial statements | Within 30 days of the AGM | 30 October 2026; fee-free till 31 December 2026 |
| MGT-14 | Board resolution approving accounts and Board’s report (public companies) | Within 30 days of the resolution | Depends on Board meeting date |
| MGT-7 / MGT-7A | Annual return | Within 60 days of the AGM | 29 November 2026; fee-free till 31 January 2027 |
| CRA-4 | Cost audit report (where applicable) | Within 30 days of receiving the report | Depends on report date (report due to Board within 180 days of year end) |
| MSME-1 | Dues to MSMEs over 45 days (Apr–Sep 2026) | Half-yearly | 31 October 2026 |
| DPT-3 | Return of deposits / outstanding loans | Annual | 30 June 2026, relaxed to 31 July 2026 (Circular 02/2026) |
| DIR-3 KYC Web | Director KYC | Now once in three financial years, by 30 June | Check each director’s cycle; changes to be updated within 30 days |
If your AGM was held earlier, or extended
- AOC-4 and MGT-7 run from the actual AGM date. A company that held its AGM on 15 September 2026 had a statutory AOC-4 date of 15 October 2026, but it too can now file without additional fees until 31 December 2026.
- Where the Registrar extended the AGM, the normal statutory timeline applies from that later AGM. For example, an AGM held on 20 December 2026 gives an AOC-4 date of 19 January 2027 and an MGT-7 date of 18 February 2027.
A quick note for LLP clients
The circular applies only to companies. For LLPs, Form 11 (annual return) was due on 30 May 2026, and Form 8 (Statement of Account and Solvency) is due on 30 October 2026. LLPs should not rely on the company-law relief for Form 8.
4. A practical plan for the remaining season
The extra time is a genuine opportunity to file carefully rather than in a rush. A sensible sequence:
- Close what is not covered first. Complete MSME-1 by 31 October 2026, and file ADT-1 and any pending MGT-14 without waiting for the relief window.
- Aim to file AOC-4 in the first half of December. This leaves a buffer for portal slowdowns, pre-scrutiny errors and resubmissions.
- Plan XBRL work early. Companies required to file AOC-4 (XBRL) or CRA-4 should validate the instance documents well ahead of the deadline.
- Prepare MGT-7 in early January. Shareholding pattern, director details, meetings held and remuneration data all need to match the financial statements already filed.
- Check DSCs and director details. Expired digital signatures and inactive DINs are the most common last-minute blockers.
- Keep the SRNs and challans. File the acknowledgements in the company’s statutory records for future reference.
5. Key takeaways
- AOC-4 and its variants for FY 2025-26 can be filed without additional fees up to 31 December 2026.
- MGT-7 and MGT-7A can be filed without additional fees up to 31 January 2027.
- The AGM deadline and other forms such as ADT-1, MGT-14, CRA-4 and MSME-1 are unchanged.
- A filing made after the relaxed date pays additional fees from the original due date.
- Filing early in the window is the simplest way to stay well clear of portal issues.
How Mittal & Company can help
Our team assists with end-to-end ROC compliance, from audit and finalisation of accounts to XBRL tagging and filing of AOC-4, MGT-7, ADT-1 and related forms on the MCA V3 portal. Reach out to plan your company’s filings well within the extended window.
Disclaimer: This article is for general information and is based on MCA General Circular No. 05/2026 dated 24 October 2026 and the Companies Act, 2013 as in force on the date of writing. It does not constitute professional advice. Please verify the position applicable to your company before acting.