Last reviewed: 25 September 2026. Form DPT-3 is an easily missed annual filing that catches many companies out - because it applies even to loans from directors and advances from customers, not just formal deposits. This guide explains what DPT-3 reports, who must file, the due date, the amounts covered, the auditor certificate and the penalty for missing it, with a worked example.
At a glance
What DPT-3 reports
DPT-3 captures money a company has received that is either a deposit or an amount not considered a deposit under rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules, 2014 - loans from directors, banks and group companies, advances from customers against supply, and similar. The purpose is transparency on all borrowed and received funds as at the year end, reported against balances on 31 March.
| Item | Deposit or not? | In DPT-3? |
|---|---|---|
| Loan from a director, with a written declaration that it is not from borrowed funds | Not a deposit | Yes, as an exempted amount |
| Loan from a relative of a director of a private company, with the same declaration | Not a deposit | Yes |
| Loan from a holding, subsidiary or associate company, including a foreign parent | Not a deposit | Yes |
| Term loan or working capital from a bank or public financial institution | Not a deposit | Yes |
| Advance from a customer, adjusted against supply within 365 days | Not a deposit | Yes |
| Customer advance not adjusted against supply within 365 days | Can be treated as a deposit | Yes, and it needs attention beyond reporting |
| Trade payables for goods and services bought on credit | Not a deposit | Generally no |
Who must file and by when
Every company other than a government company - private, public, OPC or small - with reportable amounts must file by 30 June for the year ended 31 March. Banking companies, NBFCs registered with RBI and housing finance companies registered with the National Housing Bank are outside the Deposit Rules altogether. The MCA occasionally notifies extensions, as it did for FY 2025-26, so check the current year's position.
Certificate, penalties and late fees
Rule 16 requires the particulars of deposits to be audited, so a company reporting deposits attaches an auditor's certificate; amounts that are not deposits are reported without it. Under rule 21, a contravention can attract a fine of up to Rs 5,000 on the company and every officer in default, plus up to Rs 500 for each day it continues. A late return also carries additional fees under the Companies (Registration Offices and Fees) Rules, 2014, rising with the delay:
| Delay | Additional fee |
|---|---|
| Up to 30 days | 2 times the normal filing fee |
| 31 to 60 days | 4 times |
| 61 to 90 days | 6 times |
| 91 to 180 days | 10 times |
| More than 180 days | 12 times |
It is also a common gap surfaced in due diligence - so treat DPT-3 as part of your annual ROC calendar alongside AOC-4 and MGT-7.
Worked example: a startup with a foreign parent
A Thane private company, a subsidiary of a US parent, has these balances on 31 March 2026:
- Rs 25 lakh lent by a director, with the required declaration: exempted amount, reported.
- Rs 1 crore lent by the US parent as external commercial borrowing: exempted as a loan from the holding company, reported.
- Rs 8 lakh advance from an Indian customer received in March 2026 for supplies due in May 2026: exempted as an advance against supply, reported.
- Rs 3 lakh advance received in January 2025 with no supply made by 31 March 2026: more than 365 days have passed, so it can be treated as a deposit. The company should refund or adjust it and take advice, and any deposit portion needs the auditor's certificate.
All four lines go into one DPT-3. The ECB is also reported to RBI through the company's bank, including the monthly ECB-2 return, which DPT-3 does not replace. Our foreign subsidiary accounting and FEMA service covers that side for Indian subsidiaries of overseas groups.
Frequently asked questions
What is Form DPT-3?
DPT-3 is an annual return that companies file with the Registrar of Companies under rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, reporting money received that is either a deposit or an amount not treated as a deposit - such as loans, advances from customers, and money from directors or holding companies.
Who has to file DPT-3?
Every company other than a government company - including private limited, public, OPC and small companies - must file DPT-3 if it has any outstanding loans or amounts covered by the rule as at the year end. Banking companies, NBFCs registered with RBI and housing finance companies registered with the NHB are outside these rules.
What is the due date?
The annual return is due by 30 June for the financial year ended 31 March, reporting balances as on 31 March. For FY 2025-26, MCA extended the date to 31 July 2026; that has passed, so late returns now carry additional fees. The next return, for FY 2026-27, is due by 30 June 2027.
What amounts are reported?
Both exempted deposits (loans from directors, banks, holding/subsidiary companies, advances against supply) and any actual deposits. The idea is transparency on all borrowed and received money.
Is an auditor's certificate needed?
Yes, for the deposit portion: rule 16 requires the particulars of deposits to be audited by the company's auditor, so a company reporting deposits attaches an auditor's certificate. Amounts not treated as deposits are reported without that certificate.
What if a company has no loans or deposits?
If there are genuinely no reportable amounts as at year end, the filing requirement may not apply, but companies often file a nil position to be safe - confirm based on your specific balances.
What is the penalty for not filing?
Rule 21 of the Deposit Rules provides for a fine of up to Rs 5,000 on the company and every officer in default, plus up to Rs 500 for every day the default continues. Late filing also attracts additional fees, and it is a common compliance gap flagged in due diligence.
Is a loan from our foreign parent company reported in DPT-3?
Yes. A loan from a holding company, including a foreign parent lending as external commercial borrowing, is not a deposit but is reported in DPT-3 as an exempted amount. The ECB also has its own RBI reporting through the bank, including the monthly ECB-2 return, which is a separate filing.
How is DPT-3 different from accepting public deposits?
DPT-3 is only a reporting return. Accepting public deposits is separately regulated with its own conditions; most private companies rely on exempted categories and simply report them in DPT-3.
We identify reportable loans and advances, obtain the certificate, and file DPT-3 on time.
ROC FilingsVirtual CFOTalk to CA Somesh Chandak & Associates - we manage DPT-3 and your ROC calendar.
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