AOC-4 and MGT-7 Annual Filing 2026: Due Dates, Late Fees and the Extension Question

ROC Compliance | RegisCorp Team

Checked on 24 October 2026. Every company registered in India has to file two things with the Registrar of Companies each year: its financial statements on Form AOC-4 and its annual return on Form MGT-7 (or MGT-7A for small companies and One Person Companies). For a company that held its annual general meeting (AGM) on the last permitted day, 30 September 2026, AOC-4 is due on 30 October 2026, which is six days from today, and MGT-7 is due on 29 November 2026. As of the latest pages we could open, the Ministry of Corporate Affairs (MCA) has not extended either date for FY 2025-26, although the Institute of Company Secretaries of India has asked for an extension to 31 December 2026. This post explains the dates, the fees, the documents, the penalties and the mistakes that cost money, and it lists what we could not confirm.

RegisCorp Consultancy LLP is a digital-first legal and compliance firm in Kota, Rajasthan, working with businesses across India. We write these guides so you can check the rules before you pay anyone, including us.

Key takeaways

• AOC-4 is due 30 days after the AGM, and MGT-7 or MGT-7A is due 60 days after it. For an AGM held on 30 September 2026, that is 30 October and 29 November 2026. If your AGM was earlier, your dates are earlier. Count from the date your AGM was actually held.
• No extension has been notified yet. ICSI wrote to MCA on 9 October 2026 asking for a one-time extension to 31 December 2026 without additional fees. The latest page we read, dated 24 October 2026, said no circular had been issued. A request is not a relief. Only a circular waives the fee.
• The late fee is Rs 100 a day per form, with no upper limit. It is charged on top of the normal filing fee. Two late forms cost Rs 200 a day.
• There is a second, separate layer of penalty. The Companies Act also provides a penalty on the company and on each officer in default. The sources we read give different amounts, so we show both and say which we could not verify.
• One Person Companies will already have passed their AOC-4 date. An OPC has no AGM, and its AOC-4 for FY 2025-26 was due 180 days after year-end, which the sources put at 27 September 2026.
• A deactivated DIN can block your filing. If a director's DIN is deactivated, the forms that need that director's signature cannot be filed. Check this before the last week.
• Last-week traffic is real. One source says the last week of October is the heaviest load of the year on the MCA portal. Start now, not on the due date.
• No amnesty scheme is open. The Companies Compliance Facilitation Scheme, CCFS-2026, has closed. Sources give 31 August 2026 and 15 September 2026 as the closing date, so we could not pin it down, but both are past.

The key numbers and dates in one place

What the two forms are

AOC-4 carries your financial statements to the Registrar. That means the balance sheet, the profit and loss account, the notes, the cash flow statement where it applies, the auditor's report and the Board's report. It is a data form with attachments, and the numbers must match the accounts that the AGM adopted.

MGT-7 is the annual return. It reports the registered office, the share capital, the shareholders, the directors and key managerial personnel, and the meetings held during the year. MGT-7A is the shorter version, and it is used by One Person Companies and small companies.

The two forms are filed separately, and they are due on different dates. Filing one does not satisfy the other. One compliance page lists "filing MGT-7 before AOC-4" among the common mistakes, since the annual return is meant to follow the accounts. File AOC-4 first.

Who files MGT-7 and who files MGT-7A

One page we read defines a small company, from 1 December 2025, as a private company with paid-up capital up to Rs 10 crore and turnover up to Rs 100 crore. Holding and subsidiary companies, Section 8 companies and companies governed by a special Act are excluded. Small companies and OPCs file MGT-7A. Everyone else files MGT-7. We could not read the rule that changed the limits, so check your status against the current definition before you choose the form.

The dates, with a worked table

Both dates depend on the day the AGM was held. The table shows how the dates move.

Three rules from the sources fill in the edge cases.

• No AGM held. The 30 and 60 days run from the last date on which the AGM could have been held, which is 30 September 2026, so the dates are 30 October and 29 November 2026. A late AGM does not move the due date.
• AGM extended by the Registrar. If you applied to the Registrar for more time to hold the AGM and it was granted, the 30 and 60 days run from the AGM actually held within the extended period.
• First AGM. A company holding its first AGM must hold it within nine months of the first year-end, and one page says the Registrar cannot extend that.

The 29 October reading

One page we read advises filing AOC-4 by 29 October, because some calendars count the AGM day itself and arrive at 29 October. Most pages count 30 days from the day after the AGM and arrive at 30 October. We could not resolve this from the rule text. If your filing is close, treat 29 October as the safe date. It costs nothing to file a day early.

If the accounts were not adopted at the AGM

One page says that if the AGM does not adopt the accounts, a provisional AOC-4 is due within 30 days of the AGM, and the final AOC-4 is due within 30 days of the adjourned meeting. We have not seen this confirmed in the form instructions.

The extension question

On 9 October 2026, ICSI wrote to MCA asking for a one-time extension of the AOC-4 and MGT-7 dates to 31 December 2026, without additional fees. The reasons given in the news coverage were load on the version 3 portal and expanded disclosures in the forms. The same letter pointed to the income tax relief of 28 September 2026, which moved the tax audit report date to 21 October and the audit-case return date to 21 November. The tax relief does not change any MCA date.

What do we know about whether MCA will agree? Here is the record the pages describe.

• For FY 2024-25, MCA gave relief twice. General Circular 06/2025 of 17 October 2025 allowed filing without additional fees up to 31 December 2025. General Circular 08/2025 of 30 December 2025 extended that to 31 January 2026. One page says this came just after revised forms were deployed on the version 3 portal.
• The same page says it found no annual filing relief for FY 2022-23 or FY 2023-24.
• For FY 2025-26, the pages we read say the 2026 circulars cover only CCFS-2026 and the DPT-3 return, and none covers AOC-4 or MGT-7.

So there is a precedent for last-minute relief, and there is a precedent for none. Nobody can tell you which way this year goes. Our advice is the one the careful pages give: do not plan around an extension that has not been notified. If you wait and no circular comes, the cost is Rs 100 a day per form with no ceiling. If you file now and a waiver comes later, you have lost some of the benefit of waiting, but you have not lost money you can measure.

One more caution. The fee waiver in last year's relief applied to filings within the extended window. A waiver rarely covers a company that was already late. If your AGM was in August and your AOC-4 was due in September, you are probably already counting the additional fee.

How to check: look in the Circulars section of the MCA portal or the Ministry's official handles. Do not rely on a screenshot or a forwarded message.

Fees: what you pay

Normal filing fee

The government fee depends on the authorised share capital, and it is charged per form. The slabs reported by two pages are:

Professional fees, the digital signature certificate and any audit or certification charges come on top. We do not quote professional fees, because they vary and we would be guessing.

Additional fee for late filing

The additional fee is Rs 100 for each day of delay, for each form, with no upper limit. It applies equally to small companies and OPCs. It is charged by the portal when you file, and it is separate from any penalty a court or the Registrar may impose.

A worked example: one month late

Take a company with authorised capital of Rs 10 lakh, whose AGM was on 30 September 2026.

• AOC-4 is due on 30 October. The company files on 30 November, which is 31 days late.
• The normal fee is Rs 400. The additional fee is 31 times Rs 100, which is Rs 3,100. The total is Rs 3,500.
• MGT-7 is due on 29 November. If it is filed on 5 December, that is 6 days late. The normal fee is Rs 400 and the additional fee is Rs 600, so the total is Rs 1,000.

The company has paid Rs 4,500 to file two forms that would have cost Rs 800 on time. The extra Rs 3,700 bought nothing.

A worked example: waiting for an extension that does not come

Suppose the owner of the same company decides to wait for an extension, and none arrives. She files AOC-4 on 14 February 2027 and MGT-7 on the same day.

• AOC-4 is 107 days late: 107 times Rs 100 is Rs 10,700.
• MGT-7 is 77 days late: 77 times Rs 100 is Rs 7,700.
• The additional fees total Rs 18,400, plus the normal fees of Rs 800.

If two directors also have deactivated DINs, reactivation costs Rs 5,000 each according to the pages we read, which adds Rs 10,000. That brings the bill near Rs 29,000 for a company that could have filed in October for Rs 800. The numbers are illustrative, but the arithmetic is the reason to file early.

Penalties and consequences

Beyond the additional fee, the Companies Act provides penalties for not filing financial statements and not filing the annual return. The sources we read disagree on the amounts.

We could not read the sections or the latest amendments, so we do not know which column is current. The difference is large, so do not assume the lower number. One page adds that filing within 30 days of a Registrar's notice avoids the penalty under a proviso to Section 454(3), though not the additional fee. We have not seen the proviso.

The practical point holds either way. A company that files late pays the additional fee for certain. It may also face a penalty, and its directors can become personally exposed, which matters most for the consequences below.

Director disqualification

If a company does not file its financial statements or annual returns for three continuous financial years, its directors are reported as disqualified for five years. A disqualified director cannot be appointed or reappointed in any company during that period. For a founder with several companies, one neglected shell can put every other directorship at risk.

Strike-off

The Registrar can strike a company off the register after a period of non-filing and a notice. Striking off by the Registrar is not a tidy exit. Our separate post on closing a company explains why a voluntary closure is usually better than being struck off.

Documents to have ready

The attachments differ by company. The pages we read agree on this working checklist.

For AOC-4

• Audited financial statements, signed by the board and the auditor, as a signed PDF. Companies that file in XBRL must also upload a signed PDF with the XBRL file, according to one page.
• The Board's report, with its annexures, and the auditor's report, including the CARO report where it applies.
• AOC-1, if the company has subsidiaries, associates or joint ventures.
• AOC-2, the related-party contracts statement, annexed to the Board's report.
• The CSR report and Form CSR-2, where Section 135 applies.
• The secretarial audit report in Form MR-3, where Section 204 applies.
• A statement of facts and reasons if the AGM was not held, and the Registrar's approval if the AGM was extended.
• The notice of the AGM.

For MGT-7

• The registers of members and directors, and the minutes of Board and general meetings.
• The certified annual return. The compliance certificate by a practising company secretary in Form MGT-8 is reported to be required for listed companies, and for companies with paid-up capital of Rs 10 crore or more or turnover of Rs 50 crore or more.
• The signatories. One page says the annual return is signed by a director and the company secretary, or by a practising company secretary where there is none. Small companies and OPCs sign with the company secretary, or a director if there is none.

New disclosures reported for the version 3 forms

Three pages mention changes since the forms moved to the MCA version 3 portal in July 2025.

• The Board's report now carries a declaration on compliance with the Maternity Benefit Act, 1961, and fuller disclosure of complaints under the POSH law.
• The revised form has a table for secretarial audit qualifications, and e-AOC-1 is an e-form that needs certification by a practising company secretary or chartered accountant.
• Linked forms, such as CSR-2, are filed together with AOC-4.
• A page we read says the forms ask for a photograph of the registered office, its latitude and longitude, and contact details, since 14 July 2025.

One of these pages contradicts itself on whether the Board's and auditor's report extracts are attached as PDFs, so read the form's instructions on the day.

XBRL

A company must file AOC-4 in XBRL if it is listed or a subsidiary of a listed company, has paid-up capital of Rs 5 crore or more, has turnover of Rs 100 crore or more, or prepares accounts under Ind AS. Once a company files in XBRL, it is reported to keep doing so even if it falls below the limits. Banks, insurers and housing finance companies are outside the XBRL rules. Most small private companies do not need XBRL.

Filing step by step

1. Finish the accounts and hold the AGM. The filing follows the AGM. Without an adopted set of accounts, there is nothing to file.
2. Check director and signatory status. Each director who signs needs an active DIN and a valid digital signature certificate. See our post on director KYC.
3. Prepare the attachments from the list above and confirm that the figures match the adopted accounts.
4. File AOC-4 on the MCA portal, or the XBRL or consolidated variant if it applies. Sign with the director's and the professional's digital signature, pay the fee and save the receipt with the SRN.
5. File MGT-7 or MGT-7A once AOC-4 is processed.
6. Save the SRN and the filed form with your records, and check on the portal that the status shows as approved.

Start at least two weeks before the due date if you can. If the first attempt fails on a PAN mismatch or an expired digital signature, you will want days to fix it, not hours.

Common mistakes that cost money

• Waiting for an extension. The cost of being wrong is Rs 100 a day per form with no ceiling.
• Counting from the wrong date. The dates run from the AGM, not from the year-end, and a late AGM does not move them.
• Filing MGT-7 before AOC-4. The annual return is meant to follow the accounts.
• An expired digital signature or an inactive DIN. Both block the filing at the last minute.
• A mismatch between the form and the adopted accounts. The Registrar compares them.
• The wrong form variant. AOC-4 and AOC-4 XBRL are not interchangeable, and the small-company return is a different form.
• A missing Board's report or auditor's report. The form will not go through.
• Ignoring other forms due this month. AOC-4 shares the week with the MSME-1 return and, for LLPs, Form 8. See our posts on LLP annual compliance and the half-yearly MSME-1 return.
• Treating a dormant company as exempt. A company with no business still files. Both forms are due every year, with nil figures if needed.
• Choosing the wrong financial year when clearing old backlogs. A common error when catching up several years at once.

A worked example: a small private company in Kota

Here is how the rules apply to a company with ordinary facts. The numbers are illustrative.

Ravi and his sister run a small trading company in Kota. It has authorised capital of Rs 5 lakh, turnover of Rs 60 lakh and an audit by a local chartered accountant. They held the AGM on 29 September 2026, the day before the deadline.

• Dates. AOC-4 is due on 29 October 2026 and MGT-7A on 28 November 2026, since both run from the 29 September AGM. Because the company is small, it files MGT-7A.
• Fees. Authorised capital of Rs 5 lakh falls in the Rs 400 slab, so the two forms cost Rs 800 on time.
• Preparation. Ravi checks that both directors' DINs are active, that digital signatures are valid and that the audited accounts match what the AGM adopted. He attaches the Board's report with the maternity benefit declaration, the auditor's report and the AGM notice.
• Filing. He files AOC-4 on 15 October, waits for approval and files MGT-7A on 20 October.

Total government cost: Rs 800. If he had waited for a possible extension and filed in February, the additional fees alone would have been about Rs 18,000. The difference is not clever planning. It is a short list of checks done two weeks early.

What this means for different kinds of company

A private limited company with an audit

You have the longest checklist and the most to lose. Confirm the AGM date, the auditor's appointment filing (ADT-1) and the Board's report disclosures. If your authorised capital is large, your normal fee is Rs 600 per form.

A small company or OPC

You file MGT-7A, and your penalty caps may be halved under Section 446B, though the additional fee is not. An OPC has no AGM, and its AOC-4 date has already passed according to the sources we read, so check that you have not missed it.

A Section 8 company

The same annual filings apply. See our post on registering a Section 8 company for the other yearly filings that a not-for-profit carries.

A company that has been dormant for years

The forms are still due. If the company has no future, closing it formally costs less than filing nil returns for years. Our post on closing a company sets out the options.

Frequently asked questions

What is the due date of AOC-4 for FY 2025-26?

30 days after the AGM. For an AGM held on the last permitted day, 30 September 2026, that is 30 October 2026. If you held the AGM earlier, your date is earlier.

What is the due date of MGT-7?

60 days after the AGM, which is 29 November 2026 for an AGM on 30 September 2026. Small companies and OPCs file MGT-7A on the same timeline.

Has MCA extended the AOC-4 and MGT-7 dates?

Not as of the pages we read on 24 October 2026. ICSI asked for an extension to 31 December 2026 on 9 October 2026. For FY 2024-25, MCA did give relief to 31 December 2025 and then 31 January 2026. Check the Circulars section of the MCA portal.

What is the late fee?

Rs 100 for every day of delay, for each form, with no upper limit.

Is there a penalty on top of the late fee?

The Companies Act provides one. The amounts reported for it differ between sources, so we could not confirm them. Assume the penalty is possible and the late fee is certain.

Do I have to file if my company did no business?

Yes. Both forms are due every year, with nil figures if necessary.

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

MGT-7A is the shorter annual return for One Person Companies and small companies. MGT-7 is for everyone else.

Who signs the annual return?

A director and the company secretary, or a practising company secretary if there is none. For small companies and OPCs, a company secretary signs, or a director if there is none.

Do I need a company secretary certificate for MGT-7?

A certificate in Form MGT-8 is reported to be needed for listed companies and for companies with paid-up capital of Rs 10 crore or more or turnover of Rs 50 crore or more. Smaller companies are reported to be outside it.

What if the AGM was not held?

The due dates are counted from the last date on which the AGM should have been held, which is 30 September 2026, unless the Registrar extended the AGM.

My director's DIN is deactivated. Can I still file?

A deactivated DIN is reported to block the filings that need that director. Reactivate it first. The fee is reported as Rs 5,000 per DIN.

Is a company with a loss exempt?

No. The forms are about reporting, not profit.

Can I revise the form after filing?

We did not find a clear answer. Check the draft carefully before you pay and sign, and ask a professional about corrections if you find an error after approval.

What happens if I do not file for three years?

The Registrar may strike the company off, and the directors are reported to face disqualification for five years under Section 164(2).

Is XBRL needed for my company?

Only if you are listed, a subsidiary of a listed company, have paid-up capital of Rs 5 crore or more, turnover of Rs 100 crore or more, or follow Ind AS. Most small private companies do not need it.

What to do next

1. Write down the date of your AGM. Add 30 days for AOC-4 and 60 days for MGT-7 or MGT-7A.
2. Check that each director's DIN is active and the digital signature is valid.
3. Make sure the audited accounts, the Board's report and the auditor's report are signed and match what the AGM adopted.
4. File AOC-4 this week, ideally by 29 October, and MGT-7 or MGT-7A after it is approved.
5. Do not wait for an extension that has not been notified. If one comes, you will have lost little.
6. Keep the SRN, the filed form and the receipt.

If you want help with ROC filings, annual accounts, director KYC or closing a company, contact RegisCorp. You can also read our general guide to ROC compliance for a private limited company.

This post is general information, not legal advice. Rules change, so check your facts with a qualified professional before you act.

Sources and what we could not verify

Sources used

• TaxAJ, AOC-4 and MGT-7 due dates for FY 2025-26: due dates, AGM table, late fee, extension status as of 14 October 2026.
• Careerindia, MCA annual filing deadline 2026: the ICSI request of 9 October 2026. Published 13 October 2026.
• CalcGuru, AOC-4 filing FY 2025-26: fee slabs, attachments, penalties, XBRL rules and a worked example. Reviewed 11 October 2026.
• CalcGuru, MGT-7 and MGT-7A: who files which, signatories and the MGT-8 thresholds.
• IncorpX, AOC-4 and MGT-7 annual return filing: contents of the forms, attachments and mistakes.
• IncorpX, AOC-4 MGT-7 due date extension: history of past extensions and the circulars cited.
• TaxGST, AOC-4 due 30 October 2026: status as of 24 October 2026, the 29 October reading and a checklist.
• CorpLawUpdates, Form AOC-4 filing FY 2025-26: changes in the version 3 forms. Published 13 June 2026.

All of these are secondary or commercial sources, and several promote the publisher's own services. We did not open the MCA portal, the Companies Act or the circulars themselves.

What we could not verify

• Whether MCA has issued any circular on AOC-4 or MGT-7 for FY 2025-26 since 24 October 2026, and whether it will accept the ICSI request.
• The amounts of the penalties under Sections 137(3) and 92(5), which the sources give in two incompatible ways.
• The current definition of a small company, including the limits said to apply from 1 December 2025.
• The fee slabs on the MCA payment screen, which we took from consultancy pages.
• Whether the due date is read as 29 or 30 October when the AGM is on 30 September.
• The reported photograph and geo-tag requirement for the registered office, and whether the Board's report extracts are attached as PDFs.
• The proviso that waives the penalty if the company files within 30 days of a Registrar's notice.
• The closing date of CCFS-2026, given as 31 August in one source and 15 September in others.
• The DIN reactivation fee of Rs 5,000, which we took from consultancy pages.
• The treatment of a company whose accounts were not adopted at the AGM.