A private limited company must file its audited financial statements in Form AOC-4 within 30 days of the Annual General Meeting under Section 137 of the Companies Act 2013. Because the AGM must be held by 30 September for an April–March financial year, the practical AOC-4 deadline is 30 October. Filing late attracts an additional fee of ₹100 per day per form under Section 403, with no upper ceiling — the cost simply grows until the form is filed.
Since MCA21 V3 (June 2025): AOC-4 is filed exclusively on the V3 portal, and an unfiled form stamps the company "ACTIVE-non-compliant" in the public master data. The 30-days-from-AGM deadline is unchanged.
What the law actually requires
Section 137(1) of the Companies Act 2013 requires every company to file a copy of its financial statements — the balance sheet, profit and loss account and accompanying documents — with the Registrar of Companies, along with the Board's report and the auditor's report. The filing form is AOC-4.
The clock is anchored to the AGM, not to the financial year:
- If the AGM is held, AOC-4 is due within 30 days of the AGM.
- If the AGM is not held, the clock runs from the last date by which the AGM should have been held — 30 September for most companies — so the deadline is the same even when the meeting never happened.
The timeline for an April–March company
The 30-day count runs from the actual AGM date. An AGM held on 25 September pushes the AOC-4 deadline to 25 October; one held on 30 September pushes it to 30 October. Holding the AGM early buys extra time for the filing.
The late fee under Section 403
Section 403(1) permits the Central Government to prescribe an additional fee for forms filed after the due date. The standard additional fee for AOC-4 is ₹100 per day of delay, and there is no maximum — the additional fee accumulates daily until the form is filed, on top of the normal filing fee.
Worked example: Nexus Pvt Ltd
Nexus Pvt Ltd has a 31 March year-end (FY 2025-26). Its compliance calendar:
If Nexus files on 30 November, it pays the normal filing fee plus ₹3,600 of additional fee — and, separately, Section 137(3) exposes the company and every officer in default to penalty. A company that files three months late pays ₹9,000 per form in pure late fees before any penalty.
Practical implications
- AOC-4 is not the last step — it is the anchor for MGT-7. The annual return (MGT-7) is due within 60 days of the AGM. A company that delays the AGM delays everything downstream.
- Audit before the AGM is non-negotiable. AOC-4 attaches audited financials. If the statutory audit slips past 30 September, the AGM cannot be held on time, and the 30-day and 60-day clocks start against you from the deemed date.
- XBRL may apply. Companies that are listed, have paid-up capital of ₹5 crore or more, or turnover of ₹100 crore or more must file AOC-4 in XBRL format — preparation takes longer than a PDF filing, so the lead time is real.
- The additional fee has no cap. There is no Section 403 ceiling. The only way to stop the meter is to file. Companies with multi-year arrears should look at the MCA's one-time condonation/amnesty schemes (for example, the 2026 scheme providing up to 90% waiver of late fees) rather than letting the meter run.
- Watch the "ACTIVE-non-compliant" stamp. On MCA21 v3, an unfiled AOC-4 flags the company's status publicly, which any investor or lender sees in the master data.
Step-by-step: filing AOC-4 on time
- Close the audit before the AGM. The financial statements must be audited and signed before they are laid before members. The audit timeline, not the filing deadline, is the real constraint.
- Fix the AGM date early. The AGM must be held by 30 September; holding it in mid-September instead of on the last day buys a working week of filing runway for AOC-4.
- Determine the format. Check whether the company crosses the XBRL thresholds (listed, paid-up capital ₹5 crore or more, or turnover ₹100 crore or more). If so, build the XBRL workstream into the timeline.
- Assemble the attachments. AOC-4 attaches the balance sheet, profit and loss account, the Board's report and the auditor's report. Missing attachments are the most common reason for a bounced form.
- Run the pre-scrutiny on MCA21 V3. The portal validates the CIN, DSC, XBRL tags (where applicable) and attachments before submission. Fix errors here, not after the deadline.
- File within 30 days of the AGM with the DSC of the authorised signatory, and pay the normal filing fee — plus any Section 403 additional fee if the form is already late.
- Verify the company status. A week after filing, confirm the MCA master data reads "ACTIVE-Compliant" and that the financial statements are visible. That clean status is what diligence teams and lenders look at.
FAQ
What is the AOC-4 due date for a private limited company?
Within 30 days of the AGM. With the AGM due by 30 September, the practical deadline is 30 October for an April–March company.
What if the AGM is not held?
AOC-4 is still due within 30 days of the last date by which the AGM should have been held — 30 September for most companies — so the deadline does not move just because the meeting was skipped.
How much is the late fee?
₹100 per day per form under Section 403, with no maximum. This is in addition to the normal filing fee and separate from penalties under Section 137(3).
Can the AGM be held after 30 September?
Only with an extension from the Registrar (up to three months, applied for before the due date). Without it, the AGM is a default and the AOC-4 clock runs from the deemed date.
Do all companies file AOC-4?
All companies file AOC-4, but the format differs — XBRL for listed companies and those meeting the paid-up capital/turnover thresholds, non-XBRL for the rest.
Does filing AOC-4 also cover the annual return?
No. AOC-4 files the financial statements; MGT-7/MGT-7A files the annual return. They are separate forms with separate deadlines and separate late fees.
Sources
- Section 137, Companies Act 2013 (filing of financial statements); Section 96 (AGM timeline)
- Section 403 (additional fee for late filing); Section 137(3) (penalty)
- Companies (Filing of Documents and Forms in XBRL) Rules 2015 (XBRL requirement)
- MCA21 v3 portal; current MCA condonation/amnesty announcements
Use the ROC compliance calendar to anchor AOC-4 to your AGM date. For a ROC annual-filing compliance audit of your company, visit pvtltd.co.
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