Last reviewed: 25 September 2026. Every company, whether it traded or not, must complete its annual ROC filings after the AGM - and missing them attracts an additional fee of Rs 100 per day per form with no cap, separate penalties under Sections 137 and 92, and the risk of director disqualification. This guide sets out the full annual compliance calendar, the forms, the FY 2025-26 due dates, and what you need ready before filing.
At a glance
The annual compliance calendar (FY 2025-26)
| Form | Purpose | Due date (AGM 30 Sep 2026) |
|---|---|---|
| ADT-1 | Auditor appointment / ratification | Within 15 days of AGM |
| AOC-4 / AOC-4 XBRL | Financial statements | ~30 October 2026 |
| MGT-7 / MGT-7A | Annual return (7A for OPC/small company) | ~29 November 2026 |
| AOC-4 (OPC) | Financial statements of a One Person Company, which need not hold an AGM | Within 180 days of year end: 27 September 2026 |
Who must file
Annual filings apply to every company - private, public, OPC and small company - irrespective of turnover or whether it did any business. A dormant or loss-making company must still file nil returns; there is no exemption for inactivity.
MGT-7 vs MGT-7A and XBRL
Most companies file MGT-7 as the annual return, while One Person Companies and small companies file the shorter MGT-7A. Since 1 December 2025 a private company is a small company if its paid-up capital does not exceed Rs 10 crore and its turnover does not exceed Rs 100 crore (earlier Rs 4 crore and Rs 40 crore); holding and subsidiary companies, Section 8 companies and companies governed by a special Act cannot be small companies. Listed companies and those crossing prescribed capital or turnover thresholds file AOC-4 in the XBRL format; other companies file the standard AOC-4.
Before you file
- Finalise and audit the financial statements and adopt them at the AGM.
- Prepare the board's report, auditor's report and the shareholding details for the annual return.
- Intimate the auditor appointment in ADT-1 and complete any pending event-based filings.
Cost of delay
Beyond the additional fee of Rs 100 per day per form, Section 137(3) (AOC-4) and Section 92(5) (MGT-7) provide for a penalty of Rs 10,000 plus Rs 100 for each day the default continues, up to Rs 2 lakh for the company and Rs 50,000 for each officer in default. Three consecutive years of non-filing disqualifies directors under Section 164(2) for five years and can lead to the company being struck off the register. Treat these dates as non-negotiable.
A worked example
A private company holds its AGM for FY 2025-26 on 30 September 2026 but files AOC-4 on 29 November 2026, 30 days after the 30 October due date. The additional fee is Rs 100 x 30 days = Rs 3,000 on top of the normal filing fee. The Registrar can also start penalty proceedings under Section 137(3) against the company and its officers in default. Filing MGT-7 on time does not cure the late AOC-4; each form is counted separately.
Frequently asked questions
What are the main annual ROC filings for a company?
After the Annual General Meeting, a company files Form AOC-4 (financial statements) within 30 days and Form MGT-7 or MGT-7A (annual return) within 60 days. Auditor appointment is intimated in Form ADT-1 within 15 days of the AGM.
When must the AGM be held?
A company must hold its AGM within 6 months of the financial year end - so by 30 September for a year ending 31 March. A newly incorporated company gets more time for its first AGM.
What are the due dates for FY 2025-26?
With an AGM on 30 September 2026, AOC-4 is due around 30 October 2026 and MGT-7/7A around 29 November 2026; ADT-1 within 15 days of the AGM.
What is the difference between MGT-7 and MGT-7A?
MGT-7 is the annual return for most companies. MGT-7A is a shorter annual return for One Person Companies and small companies (from 1 December 2025, paid-up capital up to Rs 10 crore and turnover up to Rs 100 crore).
Do dormant or loss-making companies still file?
Yes. Annual ROC filings are mandatory for every company regardless of turnover or activity - even a company that did no business must file nil returns.
What is the penalty for late filing?
An additional fee of Rs 100 per day per form with no upper limit, on top of the normal filing fee. Separately, penalties under Section 137 (AOC-4) and Section 92 (MGT-7) can be imposed on the company and its officers in default. Prolonged default can lead to the company being struck off and directors being disqualified.
Can directors be disqualified for non-filing?
Yes. Under Section 164(2), a director of a company that fails to file financial statements or annual returns for three consecutive years is disqualified for five years.
Is AOC-4 filed in XBRL?
Certain classes of companies - such as listed companies and those above prescribed capital/turnover thresholds - file AOC-4 in XBRL format; most private companies file the standard AOC-4.
What documents are needed for AOC-4 and MGT-7?
Audited financial statements, board's report, auditor's report, details of shareholding and changes, and particulars of directors and meetings held during the year.
What is the difference between annual and event-based filings?
Annual filings (AOC-4, MGT-7) recur every year. Event-based filings - such as changes in directors, charges, or capital - are triggered by specific events and have their own separate deadlines.
We manage AGM documentation, AOC-4, MGT-7 and event-based ROC filings and track each due date with you.
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