pvtltd.co
company-compliance

AGM Deadline Is 30 September 2026: AOC-4, MGT-7 and DIR-3 KYC — Your 14-Day Checklist

Three MCA deadlines fall on 30 September 2026 for companies with a 31 March year end: the AGM itself (Section 96), DIR-3 KYC for every director, and the clock that then starts for ADT-1, AOC-4 and MGT-7. A dated 14-day checklist with the penalty for missing each one, and what changes now that CCFS-2026 has closed.

H

Harun Raaj

pvtltd.co

Three separate Ministry of Corporate Affairs (MCA) deadlines fall on 30 September 2026 — and if you are a director of a company with a 31 March financial year end, you have exactly 14 days to act. Missing any one of them triggers penalties, deactivated director identification numbers, and a cascade of blocked filings.

This guide covers what you must do, in what order, and what happens if you miss each deadline.

---

1. AGM by 30 September 2026 (Section 96(1), Companies Act 2013)

Every company registered under the Companies Act 2013 — except a One Person Company — must hold its Annual General Meeting (AGM) within 6 months from the close of the financial year. For a company with a 31 March financial year end, the AGM must be held on or before 30 September 2026 (for FY 2025-26).

What happens at the AGM:

  • Adoption of audited financial statements for FY 2025-26

  • Declaration of dividend (if any)

  • Appointment/re-appointment of directors retiring by rotation

  • Appointment or re-appointment of statutory auditor (if applicable under Section 139)

Notice requirement: A minimum of 21 clear days written notice is mandatory (Section 101, Companies Act 2013), unless a shorter notice is agreed to by members. If you are reading this on 17 September, a notice sent today cannot give 21 clear days before 30 September (the earliest AGM date on full notice would be 9 October). You may still send a shorter notice with member consent under Section 101(1) proviso, but all members must agree in writing beforehand.

Penalty for non-holding (Section 99): Company — fine up to Rs 1 lakh. Every officer in default — fine up to Rs 1 lakh plus Rs 5,000 per day for continuing default after the Registrar issues notice.

---

2. DIR-3 KYC Must Be Done BEFORE the AGM (Due: 30 September 2026)

This is the most commonly overlooked deadline — and it has a severe cascade effect.

Under Rule 12A, Companies (Appointment and Qualification of Directors) Rules 2014, every Director Identification Number (DIN) holder whose DIN was active as at 31 March 2026 must complete the annual DIR-3 KYC exercise by 30 September 2026.

From 1 October 2026, any DIN not verified through DIR-3 KYC will be marked Deactivated by MCA. A director with a deactivated DIN cannot sign any MCA V3 form — which means:

  • The AOC-4 (financial statements) cannot be filed

  • The MGT-7 (annual return) cannot be filed

  • ADT-1 (auditor appointment) cannot be filed

  • Any board resolution form (MGT-14) cannot be filed

Reactivation requires paying a flat fee of Rs 5,000 — but the deactivated DIN itself is not the only problem. Every day of delay in post-AGM filings accrues additional late fees and penalty exposure.

Two modes of DIR-3 KYC:

  • DIR-3 KYC Web (returning filers, no change in details): OTP-based, no DSC required. Takes under 10 minutes.

  • DIR-3 KYC full form (first-time filers or changed mobile/email/address): DSC required + Aadhaar OTP + email OTP.

Action: Have all your company directors complete DIR-3 KYC on the MCA V3 portal before 30 September 2026. Do not leave this for 29 or 30 September — DSC tokens can take time to associate on MCA V3, and the portal typically experiences high traffic on deadline day.

---

3. AOC-4: File Financial Statements within 30 Days of AGM

Once the AGM is held and financial statements are adopted, Form AOC-4 must be filed with the Registrar of Companies within 30 days (Section 137(1), Companies Act 2013 + Rule 12(1), Companies (Accounts) Rules 2014).

For a company holding its AGM on 30 September 2026: AOC-4 due by 30 October 2026.

Key attachments: signed financial statements, Board Report with statutory annexures, Auditor Report, Form AOC-1 if you have subsidiaries.

Penalty for late filing (Section 137(3)):

  • Company: Rs 10,000 + Rs 100 per day, maximum Rs 2 lakh

  • Officer in default: Rs 10,000 + Rs 100 per day, maximum Rs 50,000

  • Small companies (Section 446B): penalties halved

---

4. MGT-7: File Annual Return within 60 Days of AGM

Form MGT-7 (or MGT-7A for OPCs and small companies) must be filed within 60 days of the AGM (Section 92(4), Companies Act 2013).

For AGM on 30 September 2026: MGT-7 due by 29 November 2026.

Penalty (Section 92(5)): Company — Rs 10,000 + Rs 100/day, max Rs 2 lakh; officer — same, max Rs 50,000. Small companies: halved (Section 446B).

Important: Companies with paid-up share capital of Rs 10 crore or more, or turnover of Rs 50 crore or more, must certify the annual return via Form MGT-8 (a Practising Company Secretary's certificate). Crossing these thresholds mid-year requires a CS engagement — plan ahead.

---

5. MSME-1: File for April–September 2026 Period by 31 October 2026

If your company has outstanding payments to Micro or Small Enterprise suppliers beyond 45 days, you must file Form MSME-1 (half-yearly return) by 31 October 2026 — covering the April 1 to September 30, 2026 period. This is a separate obligation under Section 405, Companies Act 2013.

---

Important: CCFS-2026 Is Now Closed

The Companies Compliance Facilitation Scheme 2026 (CCFS-2026), which allowed companies to regularise overdue (past-year) annual filings at 10% of the additional fee, expired on 15 September 2026 under MCA General Circular 04/2026. No further extension has been announced.

This means: if your company had pending annual returns or financial statements from FY 2022-23, 2023-24, or 2024-25 that you did not regularise under CCFS, you must now file with full additional fees and face potential Section 454 adjudication. Contact Harun Raaj & Associates for overdue filing assistance.

---

Your 14-Day Action Checklist

By 19 September 2026:

  • [ ] All directors: complete DIR-3 KYC on MCA V3 portal (DIR-3 KYC Web for existing filers)

  • [ ] Confirm DSC tokens are valid and associated with MCA V3 user profile

  • [ ] Send AGM notice to all members (with shorter notice consent or plan AGM for first week of October with regular notice)

By 25 September 2026:

  • [ ] Board approves draft financial statements (duly convened board meeting — Secretarial Standard SS-1 applies)

  • [ ] Statutory auditor finalises audit report

By 30 September 2026:

  • [ ] Hold AGM; financial statements adopted by members

  • [ ] DIR-3 KYC completed for all DIN holders (deadline day)

By 14 October 2026:

  • [ ] File ADT-1 (auditor appointment/reappointment) — within 15 days of AGM

By 30 October 2026:

  • [ ] File AOC-4 (financial statements) — 30 days from AGM

  • [ ] File MSME-1 for Apr–Sep period (if applicable)

By 29 November 2026:

  • [ ] File MGT-7 / MGT-7A (annual return) — 60 days from AGM

---

FAQ

Q: Can I hold the AGM virtually / online?
A: As of FY 2025-26, MCA has not issued a general circular permitting virtual AGMs for all companies (the pandemic-era blanket virtual AGM permission lapsed). Unless your company is listed on a stock exchange, you will need to hold a physical AGM or obtain an ROC extension under Section 96(3). Check for any current general circular at mca.gov.in before assuming virtual AGMs are permitted.

Q: Can I apply for an extension of the AGM deadline?
A: Section 96(3) allows the Registrar to extend the AGM by up to 3 months in exceptional circumstances, on application. Apply in advance — the ROC typically requires a reason and the application should be made before the original deadline.

Q: What if my company has never filed previous-year annual returns?
A: CCFS-2026 is now closed. You will pay full additional fees (2x–12x of normal fee depending on delay). More critically, if your company has not filed for 3 consecutive financial years, the directors are already disqualified under Section 164(2) of the Companies Act 2013. Contact us for a disqualification assessment and regularisation strategy.

Q: Does CCFS-2026 cover the current year (FY 2025-26) filings?
A: No. CCFS-2026 only covered overdue filings (FY 2022-23 onwards). Current-year filings (AOC-4, MGT-7 for FY 2025-26) are fresh filings and were never within scope of CCFS.

Q: What is the small company threshold for 446B penalty reduction?
A: As of 15 September 2022, a company is a 'small company' if its paid-up share capital does not exceed Rs 4 crore AND its turnover does not exceed Rs 40 crore in the immediately preceding financial year (Section 2(85), Companies Act 2013, as amended). Small companies get a 50% penalty reduction under Section 446B.

---

This guide is based on the Companies Act 2013, Companies (Accounts) Rules 2014, Companies (Management and Administration) Rules 2014, and Companies (Appointment and Qualification of Directors) Rules 2014. Penalty amounts are as amended by the Companies (Amendment) Acts of 2019 and 2020. This is not legal advice — consult a practising CA or CS for your company's specific compliance position.

Need help with your AGM filings? View our Annual Accounts Filing service or Annual Return Filing service.

---

See Also

Ready to incorporate or sort your compliance?

Our team handles every filing. You focus on building.

Incorporate now →Talk to us