ROC Annual Filing Calendar for a Private Limited Company in India

What happens in April and at the first board meeting?

At the first board meeting of each financial year, every director discloses interests in other entities in Form MBP-1 and confirms they are not disqualified in Form DIR-8. Use the same meeting to review statutory registers, the year’s meeting plan and which conditional returns apply. Disclosures must also be updated whenever a director’s interests change.

April is a good time to reconcile the company’s master data: directors, members, paid-up capital, registered office, auditor’s appointment term and any open ROC queries. Give every source document an owner, not just the person who uploads forms. If a director appointment or capital change is planned, add its approvals and event-based filings to the calendar straight away.

MSME-1 for the October–March half-year is due by 30 April where the company owes amounts to micro or small enterprise suppliers for more than 45 days. Confirm each supplier’s Udyam classification and reconcile invoice and payment dates. Medium enterprises are outside this return, and a company with no such overdue dues has nothing to report.

What needs attention in May and June?

June brings DPT-3, due by 30 June where applicable, and DIR-3 KYC for directors whose three-year cycle falls in that year. LLPs separately file Form 11 by 30 May. Keep company and LLP obligations on distinct lines of the calendar, because they arise under different laws with different forms and fee rules.

DPT-3 reports deposits and outstanding money or loans received that are not treated as deposits. A company with no public deposits may still have reportable items such as director loans or advances. Keep the classification workings, supporting ledger balances and any auditor’s certificate required for the return.

From 31 March 2026, DIR-3 KYC is filed once every three financial years, due by 30 June. A director who completed KYC in FY 2025-26 next files between 1 April 2028 and 30 June 2028. Changes in residential address, mobile number, email or nationality must be updated through DIR-3 KYC within 30 days. Non-filing deactivates the DIN, with a ₹5,000 fee to reactivate it.

How should July to September be used for the AGM?

July and August are for closing the books, completing the audit and having the board approve the financial statements and directors’ report, so the AGM can be held on time. For a March year-end the AGM is due by 30 September, within six months of the year-end. A company’s first AGM may instead be held within nine months of its first year-end.

Check the 15-month maximum gap between AGMs and any extension granted before fixing the date. OPCs are not required to hold an AGM, so do not copy an ordinary private-company checklist. Send the notice, financial statements and reports within the required notice period and keep proof of delivery with the attendance record, minutes and resolutions.

Director KYC is no longer a September task, so keep a separate director-level tracker for each person’s three-year window. Resolve audit queries, related-party disclosures and balance confirmations before the board approves the accounts. A late discovery can require revised financial statements after the notice has already been sent to members.

Which filings follow the AGM in October and November?

After the AGM, ADT-1 is due within 15 days where an auditor is appointed or re-appointed at that meeting, AOC-4 within 30 days and MGT-7 or MGT-7A within 60 days. With an AGM on 30 September, AOC-4 falls due on 30 October and the annual return on 29 November. An earlier AGM brings all three dates forward.

ADT-1 is not an automatic annual filing: an auditor is usually appointed for a five-year term, so it is triggered only at the AGM where an appointment is made. If the AGM is not held, the filing deadlines run from the date by which it should have been held; missing the meeting does not postpone the returns.

MSME-1 for the April–September half-year is due by 31 October where applicable. LLPs file Form 8, the statement of account and solvency, by 30 October. Prepare and certify these returns well before the last date, because portal congestion near deadlines is common and an unsubmitted draft does not count as a filing.

What happens if annual company filings are late?

Late AOC-4 and MGT-7 or MGT-7A attract an additional fee of ₹100 per day per form, with no upper cap. This is separate from penalties that can be imposed on the company and its officers for default. Continued failure to file financial statements or annual returns for three years can also lead to director disqualification under section 164(2).

Count the delay separately for each form from its own due date. Keep a record of any filing attempts, portal errors, payments and acknowledgements, but do not assume a technical problem extends a legal deadline unless MCA has issued a formal relaxation. The board should review any overdue filings and approve a clear plan to bring them up to date.

LLP additional fees follow their own schedule under the LLP rules, so do not apply the company rule automatically. Likewise, the ₹5,000 DIN reactivation fee is specific to director KYC. A group with companies and LLPs needs a separate calculation and responsibility list for each entity.

How do you turn the calendar into a working compliance record?

A working calendar records, for each item, whether it applies, the trigger date, legal deadline, internal preparation date, responsible person and filing acknowledgement. Review it after every corporate event and before each board meeting, so that a generic list of dates does not hide a newly triggered obligation or a deadline that moved with the AGM.

Keep one folder for signed financial statements, reports, notices, minutes, director declarations, supplier evidence, certificates and filed forms. Version documents so nobody files an outdated directors’ report or share register. Reconcile the annual return with the financial statements and statutory registers, especially after share issues or director changes.

At year-end, carry forward open queries, the auditor’s appointment term and each director’s next KYC window. Note which returns did not apply and why. Rebuild the next year’s calendar from current facts instead of copying the old one. The result is a clear compliance trail that investors, lenders and buyers can review during due diligence.

Which event-based filings can arise during the year?

Alongside the annual cycle, many filings are triggered by events and have short deadlines, often 30 days. Common examples are DIR-12 for director appointments or resignations, PAS-3 for share allotments, CHG-1 for charges, INC-22 for a change of registered office and MGT-14 for specified resolutions. Add each to the calendar as soon as the event is planned.

These filings depend on prior approvals. A share allotment, for example, may need board and shareholder resolutions, a valuation report and FEMA reporting for non-resident investors before or after the ROC return. Plan the approval sequence first, then calculate the filing deadline from the actual date of the event.

Record each event-based filing in the same tracker as the annual returns, with the trigger date, due date, responsible person and acknowledgement. At year-end, reconcile the annual return against these filings, because MGT-7 and the statutory registers must reflect every change in directors, shareholding and charges during the year.

What is the month-by-month ROC calendar for a March year-end?