Form DPT-3 must be filed by 30 June each year under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, reporting deposits outstanding and the particulars of money or loans received that are not deposits as at 31 March — including director loans, inter-corporate loans, bank borrowings and share application money pending allotment. A company with no deposits and no outstanding non-deposit loans may not be required to file. Where deposits are reported, the form needs an auditor's certificate.
Since the 2019 one-time filing: the annual 30 June DPT-3 is the standing requirement for outstanding deposits and non-deposit loans as at 31 March. Confirm the current nil-filing position with your CA before deciding not to file.
What the law actually requires
Rule 16(1) of the Companies (Acceptance of Deposits) Rules, 2014 requires every company, other than a government company, to file Form DPT-3 annually with the particulars of (a) deposits outstanding as at 31 March and (b) money or loans received that are not deposits.
What "not constituting deposits" includes
The definition of "deposit" in Rule 2(1)(b) excludes a range of receipts that a startup or private company commonly carries — but the exclusions do not mean the amounts vanish from reporting. Rule 16(1)(b) requires them to be reported as non-deposit money/loans:
This is why most private limited companies — even those that "never took a deposit" — have a DPT-3 filing. A founder's loan to the company is one of the most common reportable items.
When you do NOT have to file
The MCA has clarified that a company which has no deposits outstanding and no outstanding money or loans that are not deposits is not required to file DPT-3.
⚠️ — practice differs on nil DPT-3 filings. Because the annual obligation is drafted broadly, many companies file a nil DPT-3 as a precaution even when they believe nothing is reportable. Confirm the current MCA position and your company's actual loan position before deciding not to file — an unfiled DPT-3 with reportable loans exposes the company to reclassification risk.
The 2019 one-time filing
In 2019, the MCA mandated a one-time DPT-3 filing for every company to report all outstanding deposits and non-deposit loans as at 31 March 2019, covering even historical amounts accepted before the Rules. That one-time exercise is over, but it is why older companies may already have a DPT-3 trail; the annual 30 June filing continues regardless.
Worked example: Ferron Components Pvt Ltd
Ferron Components Pvt Ltd has the following outstanding amounts as at 31 March 2026:
Ferron files DPT-3 by 30 June 2026 reporting the non-deposit loans. If it forgets, the ₹40 lakh director loan sits unreported — and on a later scrutiny, the department can argue it is a deposit (the director-loan exclusion has conditions), pulling the company into the far heavier deposit-acceptance penalty regime under Section 76A, which starts at ₹1 crore or twice the amount involved, whichever is lower.
Practical implications
- Pull a 31 March snapshot of every receipt. Build the DPT-3 from the balance sheet: director loans, bank borrowings, inter-corporate loans, share application money, advances. Most companies have at least one reportable line.
- Auditor's certificate for deposits. Where the company actually holds deposits, the form is filed with a certificate from the auditor confirming the amounts comply with the deposit rules.
- Directors' loans need their conditions intact. The "not a deposit" exclusion for director loans requires the amount to be genuine and within the Rule's conditions. An undocumented or interest-free advance can be recharacterised as a deposit on scrutiny.
- Missing the deadline invites a penalty and a reclassification risk. Non-filing is penalised under the Rules, but the larger commercial risk is the deposit-recharacterisation exposure. A DPT-3 on file is evidence the company treated the money as a non-deposit.
FAQ
What is the DPT-3 due date?
30 June each year, for data as at 31 March of the same year.
Is DPT-3 only for companies that took public deposits?
No. DPT-3 also reports loans and money received that are not deposits — director loans, bank borrowings, inter-corporate loans and share application money. Most startups have a reportable figure.
Do we file DPT-3 if we have no loans or deposits at all?
The MCA position is that a company with no deposits and no outstanding non-deposit loans is not required to file. Many companies still file a nil DPT-3 as a precaution. for your company.
What happens if we file late or not at all?
The company and officers in default face penalties, and unfiled loans risk being reclassified as deposits — exposing the company to the heavier deposit-acceptance penalties under Section 76A.
Do we need an auditor's certificate?
Where deposits are reported, the form requires a certificate from the auditor. For non-deposit loans, the form's certification confirms the amounts are not deposits.
Was DPT-3 required before 30 June each year?
The annual requirement is ongoing. Separately, the MCA mandated a one-time DPT-3 in 2019 to report all historical outstanding amounts as at 31 March 2019.
Sources
- Rule 16, Companies (Acceptance of Deposits) Rules, 2014; Rule 2(1)(b) (definition of deposit and exclusions)
- Form DPT-3 and MCA clarifications on nil filings
- Section 76A (penalty for contravention of deposit provisions); Section 452 (general penalty)
Use the ROC compliance calendar to anchor the DPT-3 filing to your 31 March loan position. For a ROC compliance audit of your company, visit pvtltd.co.
---
See Also
Ready to incorporate or sort your compliance?
Our team handles every filing. You focus on building.