Quick Answer: Yes. The Ministry of Corporate Affairs (MCA) has extended the FY 2025-26 annual filing dates through General Circular No. 05/2026, dated 24 October 2026.
- AOC-4 and its variants (CFS, XBRL and the NBFC Ind AS forms) 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 is not extended, and a filing made after the extended date pays additional fees counted from the original due date.
AGM done, but the filings still stuck on signatures, DSCs, or the auditor? KNM’s secretarial team can prepare and file your annual ROC forms before the extended dates. See KNM’s annual ROC compliance support
For companies that held their AGM on 30 September, AOC-4 was due on 30 October, whether they file in-house or through compliance outsourcing. On 24 October 2026, MCA gave them more time. If your company held its AGM on 30 September 2026, AOC-4 can now be filed by 31 December 2026 and MGT-7 or MGT-7A by 31 January 2027, with no additional fees.
Annual ROC filing is the yearly submission of a company’s audited financial statements (Form AOC-4) and annual return (Form MGT-7 or MGT-7A) to the Registrar of Companies under the Companies Act, 2013. Below are the eight points that matter for FY 2025-26. They cover what changed, what did not, what a late filing costs, and a checklist to work through before you file.
Last verified: 27 October 2026, against MCA General Circular No. 05/2026.
1. Is the AOC-4 and MGT-7 Due Date Extended for FY 2025-26?
Yes. MCA General Circular No. 05/2026, dated 24 October 2026, allows the FY 2025-26 financial statements and annual returns to be filed without additional fees up to the dates below.
| Form | What it files | Statutory due date (AGM on 30 September 2026) | Extended date, no additional fees | Additional fee if filed after the extended date |
|---|---|---|---|---|
| AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | Financial statements | 30 October 2026 | 31 December 2026 | ₹100 per day per form, counted from 30 October 2026 |
| MGT-7 and MGT-7A | Annual return | 29 November 2026 | 31 January 2027 | ₹100 per day per form, counted from 29 November 2026 |
The statutory dates in the table assume an AGM on 30 September 2026, the last day available to most companies with a 31 March year end. If your AGM was earlier, your statutory dates were earlier too: count 30 days from the AGM for AOC-4 and 60 days for MGT-7.
2. What AOC-4 and MGT-7 Actually File
AOC-4 files the company’s financial statements, and MGT-7 files its annual return. They are separate forms under sep
arate sections of the Companies Act, 2013, and both are due every year.
| Point | AOC-4 | MGT-7 / MGT-7A |
|---|---|---|
| Purpose | Files the audited financial statements with the Registrar of Companies | Files the annual return: share capital, shareholders, directors, meetings, and other company details |
| Section of the Companies Act, 2013 | Section 137 | Section 92 |
| Statutory time limit | Within 30 days of the AGM | Within 60 days of the AGM |
| Which version to use | AOC-4 (XBRL) for companies covered by the XBRL rules, AOC-4 (CFS) for consolidated statements | MGT-7A for small companies and One Person Companies, MGT-7 for all other companies |
| Main attachments | Balance sheet, profit and loss account, board’s report, auditor’s report | List of shareholders and debenture holders, MGT-8 certificate where required |
Two thresholds decide extra work. XBRL filing applies to listed companies and to companies with paid-up capital of ₹5 crore or more or turnover of ₹100 crore or more, among others. An MGT-8 certificate from a practising company secretary is needed for listed companies and for companies with paid-up capital of ₹10 crore or more or turnover of ₹50 crore or more.
3. The AGM Deadline Has Not Moved
The circular is clear that it does not extend the time for holding an AGM. Only the filing window after the AGM has been relaxed.
- Regular AGM: a company with a 31 March year-end must hold its AGM within six months of the year-end, which means by 30 September (Section 96).
- First AGM: a new company must hold it within nine months of the close of its first financial year.
- Missed AGM: a company that did not hold its AGM on time remains liable under the Act, and the extended filing dates do not cure that default.
4. Only the Listed Forms Get Relief
The relaxation covers the AOC-4 series and MGT-7 and MGT-7A, and nothing else. Other filings linked to the AGM keep their normal timelines.
- ADT-1: the form reporting the appointment of an auditor is due within 15 days of the meeting at which the auditor is appointed. It is not part of this circular.
- LLP filings: LLP annual forms fall under the Limited Liability Partnership Act, 2008, and are outside a circular issued for companies.
- Other event-based forms: changes in directors, registered office, or share capital follow their own due dates.
5. What a Late Filing Costs After 31 December or 31 January
A filing made after the extended date pays all applicable fees, including additional fees, and those additional fees are counted from the date the filing was originally due under the Act, not from the extended date. Under the Companies (Registration Offices and Fees) Rules, 2014, the additional fee for a delayed AOC-4 or MGT-7 is ₹100 for each day of delay, for each form.
| Scenario (AGM on 30 September 2026) | AOC-4 filed on 10 December 2026 | AOC-4 filed on 15 January 2027 |
|---|---|---|
| Within the extended window? | Yes | No |
| Additional fee counted from | Not applicable | 30 October 2026, the original due date |
| Days of delay counted | Nil | About 77 days |
| Additional fee | Nil | About ₹7,700, plus the normal filing fee |
Missing 31 December by two weeks therefore costs almost eleven weeks of additional fees. The fee is not the only consequence:
- Penalties: Sections 92 and 137 carry separate penalties on the company and its officers in default for not filing the annual return or financial statements.
- Director disqualification: Under Section 164(2), a director of a company that has not filed financial statements or annual returns for three continuous financial years is disqualified from reappointment and from joining other companies for five years.
6. Why Filing Early Still Makes Sense
The extension removes the additional fee until the new dates, but it does not make the work smaller. Reasons to file well before 31 December:
- Audit fixes need time: if the portal or a reviewer flags an issue, you want weeks, not days, to correct it.
- Deadline weeks are crowded: professionals, signatories and DSC providers are busiest in the last fortnight before any extended date.
- AOC-4 settles the numbers: filing the financial statements first means the figures are final before the annual return is prepared.
- ADT-1 is still running: an auditor appointment at the AGM has its own 15-day clock.
7. Pre-Filing Checklist for AOC-4 and MGT-7
Use this list before anyone opens the MCA V3 portal. For newer companies, most of these items overlap with routine post-incorporation services, so the same team often handles both.
- AGM held, minutes signed, and the date of the AGM recorded.
- Financial statements approved by the board and signed as required by Section 134.
- Auditor’s report signed, with its UDIN generated.
- Board’s report approved, with all annexures.
- Digital signatures (DSCs) of the signing director and professional valid and registered on the MCA portal.
- KYC status of every director active on the MCA records.
- Shareholding at year-end reconciled with the register of members, including allotments and transfers during the year.
- Details of board, committee, and general meetings held during the year, with attendance.
- MGT-8 certificate obtained if the company crosses the thresholds above.
- XBRL applicability checked, and the XBRL file validated where it applies.
- ADT-1 filed within 15 days if an auditor was appointed or reappointed at the AGM.
- A practising professional ready to certify the forms where certification is required.
8. Where Companies Lose Time, and Where Compliance Outsourcing Helps
Most late filings are not caused by the forms themselves. They come from the steps before the upload.
- Late audit sign-off: the auditor’s report and UDIN arrive days before the deadline.
- Expired DSCs: a signing director’s DSC lapses and renewal takes time.
- Shareholding mismatches: allotments or transfers during the year are not reflected in the register, which is common in foreign-owned subsidiaries where the FEMA reporting also has to match.
- Signatories abroad: directors of Indian subsidiaries who sit at the parent company need documents early to sign across time zones.
- Scattered records: the accountant, the auditor, and the company secretary each hold part of the data, and no one owns the calendar.
Compliance outsourcing fixes the last point first: one team owns the calendar, chases the documents, and files the forms, so the company is not relying on one busy person in the finance team.
How KNM Keeps Annual ROC Filings on Schedule
For many companies, AOC-4 and MGT-7 are not difficult. They are late because they sit between the auditor, the board, and the finance team, and no one person owns them. KNM India’s secretarial services team can take that role, from tracking the AGM and filing dates to preparing and filing the annual ROC forms.
Companies that are new to India, including foreign-owned subsidiaries, can bundle annual filings with KNM’s post-incorporation services, so first-year compliance and annual filings sit with one team. Where the finance function itself needs support, KNM also offers a virtual CFO service. Together with KNM’s corporate advisory services in India and management advisory services, this gives a company one team for both its compliance calendar and its wider business decisions.
In-House Filing or Compliance Outsourcing: Which Fits Your Company?
Both routes work. The right one depends on who in your company has the time and expertise to own the calendar.
| Factor | In-house filing | Compliance outsourcing |
|---|---|---|
| Who tracks the dates | Your finance or legal team, alongside other work | An outside team that runs the compliance calendar for you |
| Best fit | Companies with a full-time company secretary and a single entity | Growing companies, foreign-owned subsidiaries and groups with several Indian entities |
| Main risk | Deadlines slip when the one person who knows the process is away | Documents must be shared early, and the provider must be chosen carefully |
| Questions to ask | Do we have a current calendar and backup signatories? | Who will file our forms, and how do they report status to us? |
If you are weighing a provider, ask who will prepare and certify the forms, how they track each date, and whether they also handle related work such as board meetings and auditor filings. Firms that offer management advisory services and corporate advisory services in India alongside secretarial work can also support decisions that come out of the annual numbers.
Frequently Asked Questions
What is the due date for filing AOC-4 and MGT-7?
Under the Companies Act, 2013, AOC-4 is due within 30 days of the AGM and MGT-7 within 60 days. For FY 2025-26, MCA General Circular No. 05/2026 allows AOC-4 to be filed without additional fees up to 31 December 2026 and MGT-7 or MGT-7A up to 31 January 2027. For a company whose AGM was on 30 September 2026, the original dates were 30 October and 29 November 2026.
Is the AOC-4 due date extended for FY 2025-26?
Yes. The circular dated 24 October 2026 extends the time for filing AOC-4, AOC-4 (CFS), AOC-4 (XBRL), and the two NBFC Ind AS versions to 31 December 2026, without additional fees. A company that files after 31 December pays the additional fee counted from its original due date, so the relief applies only to filings completed within the extended window.
Do we need to file MGT-7 every year?
Yes. Section 92 of the Companies Act, 2013 requires a company to file an annual return for every financial year, even if business was slow or nothing changed in its structure. Small companies and One Person Companies file the shorter MGT-7A, and all other companies file MGT-7. Not filing for three continuous years can disqualify the company’s directors under Section 164(2).
Who needs to file MGT-7A instead of MGT-7?
MGT-7A is the abridged annual return for small companies and One Person Companies. Every other company, including public companies and private companies that do not qualify as small companies, files MGT-7. Both forms have the same extended due date for FY 2025-26: 31 January 2027, without additional fees.
Is the AGM due date extended for FY 2025-26?
No. General Circular No. 05/2026 states that it does not extend the time for holding an AGM. A company with a 31 March year-end had to hold its AGM by 30 September 2026. Companies that missed it remain liable under the Companies Act, 2013, even though their AOC-4 and MGT-7 filing dates have been relaxed.
Does the extension apply to ADT-1 or LLP forms?
No. The circular covers only the AOC-4 series and MGT-7 and MGT-7A. ADT-1, which reports an auditor’s appointment, is still due within 15 days of the meeting that appointed the auditor. LLP annual filings fall under the Limited Liability Partnership Act, 2008, and are not covered by a circular issued for companies.
What is the penalty for not filing AOC-4 and MGT-7?
Late filing incurs an additional fee of ₹100 per day for each form, and after the extended dates, this fee is counted from the original due date. Sections 92 and 137 also carry separate penalties for the company and its officers in default. Non-filing for three continuous financial years disqualifies directors under Section 164(2).
Can a company file AOC-4 and MGT-7 before the extended dates?
Yes. The extended dates are the last days to file without additional fees, not the first. A company can file as soon as its AGM is held and its documents are ready. Filing early leaves time to correct errors, avoids the last-minute rush for signatories and DSCs, and gets the year’s compliance closed sooner.
What is the last date to file AOC-4 for FY 2025-26 without additional fees?
The last date is 31 December 2026. MCA General Circular No. 05/2026, dated 24 October 2026, allows AOC-4, AOC-4 (CFS), AOC-4 (XBRL), and the two NBFC Ind AS versions for FY 2025-26 to be filed without additional fees up to that date. After 31 December, the additional fee of ₹100 per day is counted from the company’s original due date, which was 30 October 2026 for a company that held its AGM on 30 September 2026.
What is the last date to file MGT-7 and MGT-7A for FY 2025-26?
The last date is 31 January 2027. The same circular allows MGT-7 and MGT-7A for FY 2025-26 to be filed without additional fees up to that date. The normal rule is 60 days from the AGM, so a company with a 30 September 2026 AGM originally had until 29 November 2026. A return filed after 31 January 2027 pays additional fees counted from that original date.
How do I calculate my company’s AOC-4 and MGT-7 due dates?
Start from the date of your AGM. AOC-4 is due within 30 days of the AGM and MGT-7 within 60 days. For example, a company that held its AGM on 15 September 2026 had statutory dates of 15 October 2026 for AOC-4 and 14 November 2026 for MGT-7. For FY 2025-26, both forms can still be filed without additional fees up to 31 December 2026 and 31 January 2027.
Does the extension cover AOC-4 XBRL and AOC-4 CFS?
Yes. The circular covers the whole AOC-4 series for FY 2025-26: AOC-4, AOC-4 (CFS) for consolidated financial statements, AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS). All of them can be filed without additional fees up to 31 December 2026.
Is XBRL filing mandatory for my company?
XBRL filing of financial statements applies to listed companies and to companies with paid-up capital of ₹5 crore or more or turnover of ₹100 crore or more, among other classes. Banking and insurance companies are excluded. If your company crosses either threshold, AOC-4 (XBRL) replaces the regular AOC-4, so check applicability before you prepare the filing.
What happens if the financial statements were not adopted at the AGM?
Under Section 137, if the financial statements are not adopted at the AGM, the company files the unadopted financial statements within 30 days of the AGM. Once they are adopted at the adjourned AGM, the adopted financial statements are filed within 30 days of that adjourned meeting.
Who signs the annual return in MGT-7?
Under Section 92, the annual return is signed by a director and the company secretary. If the company has no company secretary, a company secretary in practice signs instead. For small companies and One Person Companies filing MGT-7A, the company secretary signs, or a director if there is no company secretary.
Do LLPs file AOC-4 and MGT-7?
No. AOC-4 and MGT-7 are company forms under the Companies Act, 2013. Limited liability partnerships file their own annual forms under the Limited Liability Partnership Act, 2008: Form 8 for the statement of accounts and solvency, and Form 11 for the annual return. The FY 2025-26 company circular does not change LLP filing dates.
Does a company with no business still need to file AOC-4 and MGT-7?
Yes. A company that did little or no business during the year still files its financial statements and annual return. The exception is a company that has obtained dormant status under Section 455, which files a separate return for dormant companies instead. Skipping filings because the company was inactive is a common cause of director disqualification under Section 164(2).
When does compliance outsourcing make sense for annual ROC filings?
Compliance outsourcing makes sense when no one in the company owns the filing calendar, when directors sign from abroad, or when the company has several entities to manage. An outside team tracks the AGM and filing dates, collects signed documents, checks DSCs and director KYC, and files the forms, so deadlines do not depend on one busy person in the finance team.
File Before the Rush
You now have until 31 December 2026 for AOC-4 and 31 January 2027 for MGT-7, but the AGM default, ADT-1 and the fee rule have not changed. If you would rather hand the work to a team that owns the dates, talk to KNM about compliance outsourcing for your ROC filings. Contact KNM India
