Last reviewed: 5 November 2026. On 24 October 2026 the Ministry of Corporate Affairs issued General Circular No. 05/2026 (File No. Policy-17/111/2022-CL-V-MCA), titled "Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013". For FY 2025-26, the AOC-4 family can now be filed up to 31 December 2026 and MGT-7/MGT-7A up to 31 January 2027, without additional fees. This note sets out what the relief covers, what it leaves untouched, and how to plan the filing so that the concession is not lost.
What the circular says
The circular applies to annual filings for the financial year ended 31 March 2026. It does two things. It allows the listed e-forms to be filed after their normal due dates without additional fees, up to a fixed outer date. And it states the consequence of crossing that date: the filing then attracts all fees, including additional fees, as if no relaxation had been granted.
| Form | Normal due date (Companies Act) | Relaxed outer date |
|---|---|---|
| AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | 30 days from the AGM | 31 December 2026 |
| MGT-7 and MGT-7A | 60 days from the AGM | 31 January 2027 |
For a company that held its AGM on the last permitted day, 30 September 2026, the AOC-4 would normally have been due on 30 October 2026 and the MGT-7 on 29 November 2026. Both now have a longer, fee-free window. For companies that held the AGM earlier, the normal dates fell earlier and the same outer dates apply.
What is not covered
The relief is narrow, and it is worth reading it that way. The following points remain exactly as before:
- The AGM itself. The circular does not extend the time for holding an AGM and does not condone an AGM default. Whether the AGM was held by 30 September 2026, or an extension was obtained, is a separate question under Section 96. Our note on the AGM due date, GNL-1 extension and penalties explains the position.
- Other forms. ADT-1 for auditor appointment, MGT-14, DIR-12, DPT-3, MSME Form I, LLP Form 8 and event-based forms keep their own due dates. The relief is limited to the seven e-forms listed above.
- Earlier years. FY 2024-25 and older returns are outside the circular. If those are pending, the position is described in our note on what applies after CCFS-2026 closed.
- Accuracy. A fee relaxation does not validate a wrong form variant, mismatched figures or an unapproved set of accounts. Penal provisions on defective filings are unaffected.
- Normal filing fees. The relaxation is on additional fees. The standard e-form fee, based on authorised capital, is still payable.
How the additional fee works after the window
The additional fee on a delayed annual filing is Rs 100 per day of delay, per form, counted from the original statutory due date. As reported from the circular, if the form is filed after the relaxed date, the fee is computed from the original due date and not from 1 January 2027 or 1 February 2027. The relaxation is therefore a waiver for filers who stay inside the window; it is not a re-set of the clock for those who do not.
| Illustration | Original due date | Filed on | Delay counted | Additional fee |
|---|---|---|---|---|
| AOC-4, filed inside window | 30 Oct 2026 | 20 Dec 2026 | Not counted | Nil |
| AOC-4, filed after window | 30 Oct 2026 | 10 Jan 2027 | 72 days | ₹7,200 |
| MGT-7, filed after window | 29 Nov 2026 | 15 Feb 2027 | 78 days | ₹7,800 |
These figures are illustrations at Rs 100 per day. The MCA21 payment screen computes the exact amount at the time of filing, and that figure should be treated as final.
Worked example: two companies, same circular
Company A is a private limited company with a 31 March year end. It held its AGM on 28 September 2026, approved accounts on the same day, and has all reconciliations closed. It files AOC-4 on 25 November 2026 and MGT-7 on 15 December 2026. No additional fee arises on either form. It had no need to use the extra time, and nothing is lost by having filed early.
Company B held its AGM on 15 October 2026, after the 30 September due date, because the audit was delayed and no extension was sought. Its AOC-4 and MGT-7 can still use the relaxed dates and avoid additional fees. The late AGM, however, is a separate default under Sections 96 and 99 that the circular does not cure. Company B should assess that exposure with the AGM note linked above, rather than assuming the circular closes the matter.
Practical plan for the next 8 weeks
| Step | What to do | Target |
|---|---|---|
| 1 | Record the original statutory due dates for AOC-4 and MGT-7 in the compliance register. The fee clock refers back to them if the window is missed. | This week |
| 2 | Confirm the AGM date and whether it complied with Section 96. Record any extension obtained. | This week |
| 3 | Close the books, finalise the approved financial statements and tie them to the trial balance, fixed asset register and bank reconciliations. | By 20 November |
| 4 | Select the correct AOC-4 variant (standalone, CFS, XBRL, NBFC) and confirm MGT-7 or MGT-7A eligibility under the current rules. | By 25 November |
| 5 | File AOC-4, check payment, DSC validation and approval status. Do not treat an SRN alone as proof of completion. | By 15 December |
| 6 | File MGT-7 or MGT-7A after the AOC-4 data is final, so that financial and shareholding disclosures agree. | By 15 January |
Leave at least a fortnight before each outer date. MCA21 rejections and resubmissions in the final days of a relaxation window are common, and a form that is rejected after the outer date is, in practice, filed late. Our full year-end checklist is in the annual ROC compliance guide for private companies.
Common mistakes to avoid
- Reading the circular as a general extension of the AGM or of every ROC form.
- Assuming the additional fee starts only after 31 December 2026 or 31 January 2027, if the window is missed.
- Filing a MGT-7 when the company qualifies for MGT-7A, or the reverse, and then needing to re-file.
- Filing MGT-7 before the AOC-4 data is settled, leaving the two forms inconsistent.
- Relying on this note without checking the circular on the MCA website for the company's own facts.
Frequently asked questions
What has MCA announced for FY 2025-26 annual filings?
General Circular No. 05/2026 dated 24 October 2026 relaxes additional fees and extends the time for filing financial statements and annual returns for FY 2025-26. The AOC-4 family can be filed up to 31 December 2026 and MGT-7/MGT-7A up to 31 January 2027, without additional fees, if filed within those dates.
Which forms are covered?
AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS), together with MGT-7 and MGT-7A, all for FY 2025-26. Other forms such as ADT-1, MGT-14, DIR-12 and LLP Form 8 are not covered and keep their own due dates.
Does the circular extend the AGM date?
No. The circular deals with filing of financial statements and annual returns only. It does not extend the time for holding the AGM and does not cure an AGM default. Sections 96 and 99 need to be tested separately for every company.
If I file after 31 December 2026 (AOC-4) or 31 January 2027 (MGT-7), when does the additional fee start?
As reported from the circular, the additional fee is then computed from the original due date under the Companies Act, not from the day after the extended date. A late filer therefore pays the full accumulated additional fee, which is why filing inside the window matters.
Is the normal filing fee also waived?
The relief is on additional fees. Normal filing fees on the e-form continue to apply. Confirm the fee shown on the MCA21 payment screen before submitting.
Should we still file early?
Yes. A relaxation of fees does not remove the need for an accurate, approved set of accounts, a correct AOC-4 variant and a properly prepared annual return. Filing in November or early December leaves time to correct a rejection or resubmission before the outer date.
Does this help a company that missed earlier years?
No. The circular is limited to FY 2025-26. Earlier years remain under the normal additional-fee regime, because the CCFS-2026 window closed on 15 September 2026.
We prepare and file AOC-4 and MGT-7 on the information and approved accounts you provide, and keep your books reconciled so the filing is ready well before the outer date.
ROC Filing ServicesBookkeeping and AccountingTalk to usThis article summarises MCA General Circular No. 05/2026 dated 24 October 2026 for general information and is not professional advice. Check the circular text on the MCA website and your company's own facts before filing. Filing is prepared on the basis of information and approved accounts supplied by the company. Consult a Chartered Accountant for your specific situation.