pvtltd.co

Company · Annual rhythm

It's ROC season — what does our company actually have to file?

The short answer

The annual core is two filings pegged to your AGM: financial statements in AOC-4 within 30 days of the AGM, and the annual return in MGT-7 (MGT-7A for OPCs and small companies) within 60 days. Around that core, your facts decide the rest: MSME-1 if you owe micro/small suppliers beyond 45 days, DPT-3 for loans and advances, CSR-2 if CSR applies, PAS-6 for certain unlisted companies. The paper layer matters too — the board's report with its AOC-2 related-party annexure is what the AOC-4 actually carries.

What gets filed with MCA

AOC-4Financial Statement Filing

Within 30 days of the AGM (within 30 days of December 31 for OPC).

Section 137, Companies Act 2013

MGT-7Annual Return

Within 60 days of the AGM. For FY ending March 31, AGM must be held by September 30, so MGT-7 is due by November 29.

Section 92, Companies Act 2013

MGT-7AAnnual Return — OPC and Small Companies

Within 60 days of the AGM (or 60 days from December 31 for OPC, since OPC must hold its annual general meeting by December 31).

Section 92, Companies Act 2013 (proviso)

MSME-1Half-Yearly MSME Outstanding Payment Return

By April 30 (for October–March half-year) and October 31 (for April–September half-year).

Section 405, Companies Act 2013; Rule 6(3), Companies (Specification of Definitions Details) Rules 2014; MSMED Act 2006

DPT-3Annual Return of Deposits and Loans

By June 30 every year, for the position as of March 31.

Section 73(2)(e) and Rule 16, Companies (Acceptance of Deposits) Rules 2014

CSR-2CSR Annual Report

Filed with AOC-4 (within 30 days of AGM), or by March 31 where CSR-2 is filed separately as an addendum.

Section 135(9), Companies Act 2013; Rule 12(2), Companies (CSR Policy) Amendment Rules 2021

PAS-6Share Capital Reconciliation Audit Report

Within 60 days from the end of each half year (September 30 and March 31).

Rule 9A(8), Companies (Prospectus and Allotment of Securities) Rules 2014; SEBI LODR Regulation 76

MGT-8Certification of Annual Return by Company Secretary

Filed along with MGT-7 (within 60 days of the AGM).

Section 92(2), Companies Act 2013

The paperwork nobody tells you about

Statutory formats that never touch the MCA portal — but an ROC inspection or due diligence will ask for every one of them.

Board's report

Directors' report with all section 134 disclosures — adopted before the AGM, attached to AOC-4

Section 134, Companies Act 2013

AOC-2

Related-party transaction disclosure annexed to the board's report

Section 134(3)(h) read with Section 188(2), Companies Act 2013

AOC-1

Statement on subsidiaries/associates/JVs, where applicable

Section 129(3), Companies Act 2013

The sequence

  1. 1Finalise accounts and get the audit report
  2. 2Adopt the board's report (with AOC-1/AOC-2 annexures where applicable)
  3. 3Hold the AGM by 30 September
  4. 4File AOC-4 within 30 days and MGT-7/7A within 60 days of the AGM
  5. 5Clear the fact-dependent returns: MSME-1, DPT-3, CSR-2, PAS-6 as applicable

Questions founders actually ask

We had zero revenue this year — do we still file?

Yes. AOC-4 and MGT-7/7A are status-based, not activity-based. A nil-revenue company files the same core set; skipping it accrues ₹100/day per form with no upper cap on the company.

MGT-7 or MGT-7A — which one are we?

OPCs and small companies (paid-up capital ≤ ₹50 crore AND turnover ≤ ₹200 crore) file the abridged MGT-7A; everyone else files MGT-7. The form pages linked below carry the current thresholds.

When does MGT-8 certification apply?

When paid-up capital reaches ₹10 crore or turnover ₹50 crore, the annual return must be certified by a practising company secretary in MGT-8 — a paper-format certification, not a separate e-filing.

Last verified 2026-08-24 against MCA V3 records and ICSI reference material. Form-level deadlines and penalties live on the linked form pages and update there.