The Ministry of Corporate Affairs (MCA) has extended the due dates for the annual ROC forms for FY 2025-26. Through General Circular No. 05/2026 dated 24 October 2026, companies can file AOC-4 (financial statements) up to 31 December 2026 and MGT-7 / MGT-7A (annual return) up to 31 January 2027 without any additional fee. The relief is narrower than it looks, so read the conditions below before you plan your filings.
What exactly did MCA extend?
The circular was issued after stakeholders asked for more time to file the annual forms for financial year 2025-26. It allows these forms to be filed without additional fees up to the dates below.
| Form | What it is | Normal due date (AGM on 30 September 2026) | Extended date, no additional fee |
|---|---|---|---|
| AOC-4 | Financial statements | 30 October 2026 | 31 December 2026 |
| AOC-4 (CFS) | Consolidated financial statements | 30 October 2026 | 31 December 2026 |
| AOC-4 (XBRL) | Financial statements in XBRL format | 30 October 2026 | 31 December 2026 |
| AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) | Financial statements of Ind AS NBFCs | 30 October 2026 | 31 December 2026 |
| MGT-7 | Annual return | 29 November 2026 | 31 January 2027 |
| MGT-7A | Annual return of One Person Companies and small companies | 29 November 2026 | 31 January 2027 |
The normal dates come from the Companies Act, 2013. Section 137 requires financial statements to be filed within 30 days of the annual general meeting (AGM), and Section 92(4) requires the annual return within 60 days of the AGM. For a One Person Company, financial statements are due within 180 days from the end of the financial year, which is why many OPCs had an earlier date.
Is the AGM deadline also extended?
No — and this is the most important point. Paragraph 3 of the circular says it must not be read as extending the time for holding AGMs. Companies that did not hold their AGM within the time allowed are still liable under the relevant provisions of the Act.
So the extension only gives more time to upload the forms. The meeting itself had to be held on time — for most companies with a 31 March year end, by 30 September 2026, unless the Registrar had granted an extension. If your AGM was missed, speak to your adviser about the position before filing, because the forms will show the AGM date and the default will be visible.
What happens if you miss the extended dates?
This is the second trap. Paragraph 4 of the circular says that filings made after the relaxation period attract all applicable fees, including additional fees under the Companies (Registration Offices and Fees) Rules, 2014, counted from the original due date.
For delay in filing under Sections 92 and 137, those rules levy an additional fee of ₹100 per day. An example:
| Situation | How additional fee is counted |
|---|---|
| AGM on 30 September 2026, AOC-4 filed on 20 December 2026 | Within the extended period — no additional fee |
| AGM on 30 September 2026, AOC-4 filed on 5 January 2027 | Relief lost — additional fee runs from the day after 30 October 2026, not from 31 December 2026 |
| AGM on 30 September 2026, MGT-7 filed on 25 January 2027 | Within the extended period — no additional fee |
| AGM on 30 September 2026, MGT-7 filed on 10 February 2027 | Relief lost — additional fee runs from the day after 29 November 2026 |
Missing the extended date by even a few days therefore costs about two months of additional fee, not just the few days.
Which forms are not covered?
The circular names only the AOC-4 family and MGT-7/MGT-7A of companies. Everything else keeps its normal timeline and fees, including:
- ADT-1 (intimation of auditor appointment, due within 15 days of the AGM).
- MGT-14 (filing of certain board and shareholder resolutions).
- DIR-3 KYC of directors and other event-based forms.
- LLP Form 8 and Form 11. These are filed under the LLP Act, 2008, not the Companies Act, so this circular does not apply to them. LLPs should keep to their own due dates.
Are there penalties beyond additional fees?
Yes. Additional fees are only one layer. Section 137(3) and Section 92(5) of the Companies Act, 2013 also provide for penalties on the company and its officers in default where filing is not done in time:
| Default | Company | Each officer in default |
|---|---|---|
| Section 137 (financial statements) | Penalty of ₹10,000, plus ₹100 per day of continuing failure, capped at ₹2 lakh | Penalty of ₹10,000, plus ₹100 per day, penalty capped at ₹50,000 |
| Section 92 (annual return) | Penalty of ₹10,000, plus ₹100 per day of continuing failure, capped at ₹2 lakh | Penalty of ₹10,000, plus ₹100 per day, penalty capped at ₹50,000 |
Filing within the extended window avoids additional fees. It does not cure a missed AGM, which is dealt with separately under the Act.
What should companies do now?
Treat the new dates as a buffer, not a target. A practical plan:
- Confirm your AGM date and that the minutes, attendance and adoption of accounts are recorded properly.
- File ADT-1 if not already done — it is not covered by the extension.
- Prepare AOC-4 early. Signed financial statements, the auditor's report, the board's report and, where applicable, the XBRL instance file take time to assemble and validate.
- Keep DSCs valid. An expired digital signature of a director or professional is a common last-minute hold-up.
- Avoid the last week. The MCA portal tends to be slow close to any deadline. Aim to file AOC-4 by mid-December and MGT-7/MGT-7A by mid-January.
- Keep the income tax side in view. If your company is under tax audit, see our note on the ITR due date for audit cases for AY 2026-27.
Private companies can also check our overview of annual compliance for private limited companies to see the full list of yearly filings.
How Indian Salahkar can help
Indian Salahkar works closely with Company Secretaries and Chartered Accountants to help companies in Agra and across India prepare and file AOC-4, MGT-7/MGT-7A and related forms on time. See our ROC compliances service to share your documents and plan the filings before the extended dates.
Frequently asked questions
What are the extended due dates for AOC-4 and MGT-7 for FY 2025-26?
Under MCA General Circular No. 05/2026 dated 24 October 2026, all AOC-4 variants can be filed up to 31 December 2026, and MGT-7 and MGT-7A up to 31 January 2027, without additional fees.
Has the date for holding the AGM also been extended?
No. The circular says it does not extend the time for holding annual general meetings. A company that did not hold its AGM on time remains liable under the Companies Act, 2013.
What happens if AOC-4 is filed after 31 December 2026?
The relaxation is lost. Additional fees of ₹100 per day are then counted from the original due date (30 days after the AGM), not from 31 December 2026.
Are LLP Form 8, ADT-1 or DIR-3 KYC covered by this extension?
No. The circular covers only the AOC-4 family of forms and MGT-7/MGT-7A of companies. LLP forms, ADT-1, MGT-14, DIR-3 KYC and other forms keep their normal due dates and fees.
Do One Person Companies and small companies get the relief?
Yes. The circular does not exclude any class of company and expressly includes MGT-7A, the shorter annual return used by One Person Companies and small companies.
Sources: mca.gov.in · e-book.icsi.edu · e-book.icsi.edu · e-book.icsi.edu
General information, not professional advice. Rules change — check the current position before acting.
