Company shown Active non-compliant, what is blocked?

You open the MCA portal to file a form. The company master data says "ACTIVE-non-compliant". Or a filing you tried is simply not accepted. This article explains what that tag means, which filings it blocks, and how it is cleared.

What the tag actually is

"ACTIVE" stands for Active Company Tagging Identities and Verification. It is a one-time verification of a company and its registered office, filed in e-Form INC-22A (rule 25A, Companies (Incorporation) Rules 2014).

The rule applies to "every company incorporated on or before the 31st December, 2017". Such a company had to file the particulars of the company and its registered office in e-Form ACTIVE. The first deadline was 25 April 2019 (rule 25A(1), as inserted by the Companies (Incorporation) Amendment Rules 2019). It was later moved to 15 June 2019 (Companies (Incorporation) Fourth Amendment Rules 2019).

A company that did not file was to be marked "ACTIVE-non-compliant". After the extension, that marking applied on or after 16 June 2019 (rule 25A(1), third proviso, as amended by the Fourth Amendment Rules 2019).

So the tag is not a penalty notice you must respond to by a date. It is a status. It stays until the form is filed.

Does it apply to your company?

It can apply only if the company was incorporated on or before 31 December 2017 (rule 25A(1)). A company incorporated in 2018 or later is outside this rule.

The rule also says that companies that are "struck off or under process of striking off or under liquidation or amalgamated or dissolved, as recorded in the register" are not required to file e-Form ACTIVE (rule 25A(1), second proviso).

What is blocked while the tag is on

The rule is specific. The Registrar will not accept requests to record the following events from a company marked ACTIVE-non-compliant, unless e-Form ACTIVE is filed (rule 25A(1), fourth proviso):

SH-07, change in authorised capital.
PAS-03, change in paid-up capital (return of allotment).
DIR-12, changes in directors, with exceptions below.
INC-22, change of registered office.
INC-28, amalgamation or de-merger.

In everyday terms: you cannot increase authorised capital, report a new share allotment, appoint a new director, shift the registered office, or record a merger order until the tag is cleared.

The DIR-12 exceptions

Not every DIR-12 is stopped. The item was replaced by the Companies (Incorporation) Eighth Amendment Rules 2019. DIR-12 is blocked "except in case of":

cessation of any director;
appointment of directors where the total number of directors is below the minimum in section 149(1)(a) of the Companies Act 2013 because of disqualification of all or any director under section 164;
appointment of any director where the DINs of all or any of the directors have been deactivated;
appointment of directors to implement an order of a Court, Tribunal or Appellate Tribunal under the Companies Act 2013 or under the Insolvency and Bankruptcy Code 2016.

(Rule 25A(1), fourth proviso, item (iii), as substituted by the Eighth Amendment Rules 2019.)

So a director's resignation can still be filed. A routine new appointment cannot.

What is not on the blocked list

The rule names only the five forms above. It does not say that annual filings (AOC-4, MGT-7) are stopped by the tag. Do not assume they are blocked, and do not skip them. Late filing has its own consequences. If a filing will not go through, read the exact portal message and check it against the list above.

The bigger risk: action under section 12(9)

The rule also says a company that does not file "shall be liable for action under sub-section (9) of section 12 of the Act" (rule 25A(1), third proviso).

Section 12(9), Companies Act 2013 says: if the Registrar "has reasonable cause to believe that the company is not carrying on any business or operations", he may cause a physical verification of the registered office. If any default is found in having a registered office capable of receiving communications (section 12(1)), he may initiate action for removal of the company's name from the register under Chapter XVIII, without prejudice to the penalty in section 12(8).

Section 12(8) is a penalty of one thousand rupees for every day of default, up to one lakh rupees, on the company and every officer in default.

Rule 25B (inserted by the Companies (Incorporation) Third Amendment Rules 2022) lets the Registrar visit the registered office address on the basis of documents on MCA 21, in the presence of two independent local witnesses, and photograph it.

Practical meaning: an unverified registered office plus no visible activity is the combination that invites strike-off action. The tag matters more for that reason than for the blocked forms.

Before you file: the first gate

The rule has a gate in front of the form. A company that "has not filed its due financial statements under section 137 or due annual returns under section 92 or both with the Registrar shall be restricted from filing e-Form-ACTIVE" (rule 25A(1), first proviso). The only exception is a company under management dispute where the Registrar has recorded it on the register.

So the order is usually:

File the overdue financial statements (section 137, Companies Act 2013) and annual returns (section 92).
Then file INC-22A.

If the portal refuses INC-22A, an unfiled AOC-4 or MGT-7 is the first thing to check.

Step by step: filing INC-22A

The form was substituted with effect from 14 July 2025 (Companies (Incorporation) Amendment Rules 2025, G.S.R. 426(E), 27 June 2025). Use the current e-Form on the MCA portal. It asks for the following.

Company details. CIN, name, registered office address, and the latitude and longitude of the office. The company e-mail ID is verified by an OTP.
Directors. Number of directors and a list with DINs. The form warns you to make sure every DIN is "approved" and not "De-activated due to non-filing of DIR-3 KYC" or "Disqualified u/s 164(2)". Fix any DIN problem first.
Statutory auditor details. Number of auditors, category, PAN, name, membership or registration number and period of appointment.
Cost auditor details, if the company is required to appoint one.
Managing director, CEO, manager or whole-time director, the company secretary and the CFO, where applicable.
SRNs of AOC-4 (or AOC-4 XBRL) and MGT-7 filed for FY 2017-18. Have these ready.
Attachment. A photograph of the registered office showing the external building, and the inside of the office with at least one director or KMP who has signed the form digitally.
Signatures. One director for a One Person Company. For other companies, one director and one KMP, or two directors.
Professional certificate. The form must also be certified and digitally signed by a practising Chartered Accountant, Cost Accountant or Company Secretary, who states that identity and address were checked against the original attached document.

The fee in rule 25A(2) as inserted in 2019 is ten thousand rupees, on payment of which the company is marked "ACTIVE Compliant". Fees can change. Check the current fee on the MCA portal before you pay.

The deadline clock

There is no fresh statutory deadline now. The dates in the rule (15 June 2019 for filing, 16 June 2019 for the marking) have passed. The clock that matters is practical:

Each new event you need to file (new share allotment, new director, registered office shift) cannot proceed until the tag is cleared.
Section 12(8) allows a penalty of one thousand rupees a day up to one lakh rupees where the registered office requirements are not met.
Section 12(9) action can begin at any time the Registrar has reasonable cause to believe the company is not carrying on business.

What not to do

Do not file INC-22A with an office photo or address that does not match the real office. The form carries a declaration that the registered office is at the stated address. The form's note also draws attention to section 447 (fraud), section 448 (false statement) and section 449 (false evidence) of the Companies Act 2013.
Do not assume the company is safe because the filing was only blocked, not rejected. The section 12(9) route stays open.

What to do now

Next step: Check the company's master data on the MCA portal for "ACTIVE-non-compliant", and check that AOC-4 and MGT-7 are up to date (rule 25A(1), first proviso).
Deadline: None fixed now. The 2019 dates have passed. Clear the tag before any capital, director or office change you plan, because those filings are blocked until then (rule 25A(1), fourth proviso).
Consequence of waiting: The company stays "ACTIVE-non-compliant" and remains liable to action under section 12(9) of the Companies Act 2013, including a section 12(8) penalty of ₹1,000 per day up to ₹1 lakh where the default is in the registered office.

Have a CA review your facts before you act or file.

FAQs

Does the tag mean my company has been struck off?
No. It is a filing status under rule 25A. Strike-off is a separate process under Chapter XVIII of the Companies Act 2013, which section 12(9) can lead to.

My company was incorporated in 2019. Do I need INC-22A?
Rule 25A(1) applies to companies incorporated on or before 31 December 2017. A later company is outside it.

Can I still file a director's resignation?
Yes. Cessation of a director is an exception to the DIR-12 block (rule 25A(1), fourth proviso, item (iii)).

Can I file INC-22A if my annual returns are overdue?
No, not first. The company is restricted from filing e-Form ACTIVE until the due financial statements and annual returns are filed, unless it is under a recorded management dispute (rule 25A(1), first proviso).

Who signs the form?
One director for a One Person Company. One director and one KMP, or two directors, for other companies. A practising CA, CS or Cost Accountant also certifies it.

How much does it cost?
Rule 25A(2) as inserted in 2019 states ten thousand rupees. Check the current fee on the MCA portal before filing.

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