MCA extended AOC-4, MGT-7 MGT-7A Due Date for FY 2025-26

The Ministry of Corporate Affairs has provided significant relief to companies completing their annual ROC filings for FY 2025-26. Under General Circular No. 05/2026 dated 24 October 2026, the filing window for financial statements in AOC-4 has been extended to 31 December 2026, while annual returns in MGT-7 and MGT-7A can be filed up to 31 January 2027 without additional fees. 

However, the circular does not postpone the Annual General Meeting or provide a general waiver for every MCA form. Companies must still complete their accounts, audit, AGM and other statutory compliances independently. Need assistance with AOC-4, MGT-7 or complete ROC annual filing? Connect with Startup Movers⁠ to complete your company’s annual compliance accurately.

Answer at a Glance

What Has MCA Announced Through General Circular No. 05/2026?

The MCA received representations from stakeholders seeking additional time to complete annual filings under the Companies Act, 2013 for FY 2025-26.

In response, General Circular No. 05/2026 allows companies to file specified financial-statement and annual-return forms without additional fees up to the following dates:

• AOC-4 and specified variants: 31 December 2026
• MGT-7 and MGT-7A: 31 January 2027

The relief relates to annual filings for the financial year ending 31 March 2026.

The official circular is titled “Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013.”

Although the update is commonly called a due-date extension, it should be understood as an extended filing window with relaxation from additional fees for the specified forms. It does not change every underlying statutory event or compliance deadline.

What Are the Revised AOC-4, MGT-7 and MGT-7A Due Dates?

For a company that held its AGM on 30 September 2026, the usual annual filing dates and the extended fee-relief dates are:

The original statutory date may be earlier where a company held its AGM before 30 September 2026. However, the circular provides fixed calendar dates for filing the covered FY 2025-26 forms without additional fees. 

Which AOC-4 Forms Are Covered by the MCA Extension?

The AOC-4 due date extension covers the following financial-statement forms:

• AOC-4;
• AOC-4 CFS;
• AOC-4 XBRL;
• AOC-4 NBFC (Ind AS); and
• AOC-4 CFS NBFC (Ind AS).

Companies must use the correct form according to their financial-reporting requirements.

For example:

• A company not covered by XBRL or a specialised NBFC form generally files AOC-4.
• A company with subsidiaries, associates or joint ventures may also need to file consolidated financial statements through AOC-4 CFS.
• Companies covered by the prescribed XBRL rules file AOC-4 XBRL.
• Applicable NBFCs following Indian Accounting Standards use the relevant NBFC Ind AS form.

The relaxation does not remove the need to determine the correct form. Filing the wrong AOC-4 variant can result in incomplete or defective annual compliance.

What Is Form AOC-4?

AOC-4 is the MCA form used by a company to file its financial statements and related documents with the Registrar of Companies.

Depending on the company and the applicable form, the filing may include:

• Balance sheet;
• Statement of profit and loss;
• Cash-flow statement, where applicable;
• Statement of changes in equity, where applicable;
• Notes to accounts;
• Board’s report;
• Auditor’s report;
• Corporate Social Responsibility disclosures, where applicable;
• Details of subsidiaries, associates and joint ventures;
• Consolidated financial statements, where applicable; and
• Other documents prescribed under the Companies Act and applicable rules.

Section 137 of the Companies Act, 2013 generally requires financial statements to be filed within 30 days from the date of the AGM.

Where an AGM is not held, the financial statements must ordinarily be filed within 30 days from the date on which the AGM should have been held, along with the prescribed reasons and supporting information.

What Is the Difference Between MGT-7 and MGT-7A?

MGT-7 and MGT-7A are annual-return forms, but they apply to different categories of companies.

The applicable annual return generally contains information about:

• Registered office;
• Principal business activities;
• Holding, subsidiary and associate companies;
• Shares, debentures and other securities;
• Members and debenture holders;
• Promoters, directors and key managerial personnel;
• Board and committee meetings;
• Remuneration;
• Penalties and compounding;
• Shareholding pattern;
• Certification and compliance; and
• Other prescribed corporate particulars.

MGT-7A is a simplified or abridged annual return intended for OPCs and Small Companies. A company should verify its status before selecting MGT-7A.

Does the Extension Apply to OPCs and Small Companies?

Yes. MGT-7A is expressly included in the extended filing window up to 31 January 2027. Therefore, eligible OPCs and Small Companies can file their FY 2025-26 annual return in MGT-7A without additional fees up to that date.

AOC-4 is also covered generally. This means that OPCs and Small Companies using the applicable AOC-4 form can benefit from the AOC-4 filing window up to 31 December 2026.

However, an OPC’s normal AOC-4 timeline is different from that of a company holding an AGM. An OPC generally files its financial statements within 180 days from the close of the financial year. The MCA relaxation provides additional-fee relief for the covered FY 2025-26 form but does not alter the statutory framework applicable to OPCs.

Has MCA Extended the AGM Deadline?

No. The circular does not extend the statutory time for holding an Annual General Meeting.

This is one of the most important limitations of the MCA annual filing extension.

For most companies following the April-to-March financial year, the AGM for FY 2025-26 was ordinarily required to be held by 30 September 2026, subject to:

• The company’s actual incorporation and AGM history;
• First-AGM provisions; and
• Any valid extension separately granted by the Registrar of Companies.

The circular expressly clarifies that it should not be interpreted as an extension of the time allowed for holding an AGM. A company that failed to hold its AGM within the applicable time may continue to face consequences for that default. 

The relief only provides additional time to file the specified financial statements and annual returns without additional filing fees.

Are ADT-1 and DIR-12 Covered by the Extension?

No. General Circular No. 05/2026 does not cover ADT-1 or DIR-12.

This distinction is important because professional representations seeking relief had referred to additional forms, but the final MCA circular covers only the specified AOC-4 variants, MGT-7 and MGT-7A.

Therefore:

• ADT-1 continues to follow its applicable filing timeline;
• DIR-12 continues to follow its event-based filing timeline;
• Additional fees may continue to apply to delayed forms; and
• Companies should not postpone these filings based on the AOC-4 and MGT-7 extension.

The extension also should not be treated as relief for unrelated forms such as PAS-6, MSME-1, DPT-3 or other event-based filings.

Is the Normal Government Filing Fee Also Waived?

No. The circular provides relaxation from additional filing fees, not the normal government fee.

Companies filing within the extended window must still pay the normal filing fee applicable to the form. The fee generally depends on the company’s nominal share capital or its applicable filing category.

The relief can be understood as follows:

What Happens If a Company Misses the Extended Date?

The extended filing windows are:

• 31 December 2026 for AOC-4 and its covered variants
• 31 January 2027 for MGT-7 and MGT-7A

If a company files after the applicable extended date, all prescribed fees, including additional fees, become payable.

Importantly, the additional fee is calculated with reference to the form’s original statutory due date—not from 31 December 2026 or 31 January 2027. 

For example, if AOC-4 was originally due on 30 October 2026 but is filed after 31 December 2026, the additional fee may be calculated from the original 30 October deadline.

Delayed annual filing ordinarily attracts an additional fee of ₹100 per day per form, without a maximum ceiling, subject to the applicable rules. Separate statutory penalties and compliance consequences may also arise.

Therefore, the extended date should be treated as the last date for relief—not as the date on which preparation should begin.

Will MCA Refund Additional Fees Already Paid?

General Circular No. 05/2026 does not expressly provide for the refund of additional fees already paid before the relief was announced.

Therefore, a company that filed a covered form late and already paid additional fees should not assume that the amount will automatically be refunded.

Any refund or adjustment would require separate clarification or functionality from the MCA.

Why Has MCA Provided This Annual Filing Extension?

The circular follows stakeholder representations seeking additional time for FY 2025-26 annual filings.

The concerns raised by stakeholders reportedly included:

• Technical difficulties on the MCA V3 portal;
• Portal downtime and slow response;
• Session timeouts;
• Login and DSC association issues;
• Form validation errors;
• Payment difficulties;
• Increased disclosures in revised annual filing forms;
• Additional time required for data preparation; and
• XBRL tagging and validation requirements.

The extension is intended to allow companies and professionals to complete accurate filings without incurring additional fees because of the compressed annual filing schedule and practical portal challenges.

What Should Companies Do During the Extended Filing Window?

Companies should use the additional time to complete their annual compliance properly instead of waiting until the revised last date.

The following actions should now be prioritised:

1. financial statements: Ensure that the balance sheet, statement of profit and loss, notes and schedules are complete.
2. Complete the statutory audit: Obtain the signed auditor’s report and resolve pending audit observations.
3. Verify AGM compliance: Confirm the AGM date, minutes, attendance and adoption of financial statements.
4. Complete XBRL preparation: Applicable companies should complete tagging, validation and consistency checks early.
5. Reconcile MCA master data: Verify directors, share capital, registered office, charges and other company details.
6. Update statutory registers: Ensure that members, directors, share transfers, beneficial interests and meeting records are current.
7. Choose the correct annual return: Determine whether the company must file MGT-7 or qualifies for MGT-7A.
8. Review DSC validity: Ensure that the Digital Signature Certificates of directors and professionals are valid and associated with the MCA V3 portal.
9. Complete professional certification: Obtain the required CA, CS or CMA certification, as applicable.
10. File before the last week: Avoid portal congestion and last-minute validation or payment failures.

What Should Be Checked Before Filing AOC-4?

Before submitting AOC-4 or an applicable variant, verify that:

• Financial statements have been approved by the Board;
• The statutory audit has been completed;
• The auditor’s report is signed;
• The Board’s report is signed;
• Financial statements were properly adopted;
• AGM details are correctly entered;
• Figures agree with the audited financial statements;
• Consolidated accounts are included where applicable;
• Related-party and CSR disclosures are complete;
• XBRL tagging is accurate, where applicable;
• Attachments are legible and correctly named;
• DSCs are active; and
• The correct AOC-4 variant has been selected.

What Should Be Checked Before Filing MGT-7 or MGT-7A?

Before filing the annual return, verify that:

• The correct form: MGT-7 or MGT-7A, has been selected;
• Registered-office details are correct;
• Principal business activities are accurately reported;
• Share capital agrees with MCA records and financial statements;
• Shareholding details are updated;
• Director and KMP details are correct;
• Board and committee meeting information is complete;
• Transfers and allotments have been reconciled;
• Holding, subsidiary and associate relationships are correctly disclosed;
• Penalties and compounding information is reported;
• MGT-8 certification is obtained where applicable;
• The company’s DSCs are active; and
• Professional certification requirements have been completed.

Conclusion

MCA General Circular No. 05/2026 provides welcome relief for FY 2025-26 annual filings. Companies can file AOC-4 and its specified variants without additional fees up to 31 December 2026, while MGT-7 and MGT-7A can be filed without additional fees up to 31 January 2027.

The extension does not postpone the AGM or cover ADT-1, DIR-12 and other unrelated forms. Companies should use the additional time to complete accurate financial-statement and annual-return filings instead of treating the revised dates as a reason to delay. For assistance with AOC-4, XBRL, MGT-7, MGT-7A or complete company annual compliance, Connect with Startup Movers⁠