Corporate law and annual compliance

ROC Annual Filing in India: Annual Returns, Financial Statements and Due Dates

Companies registered in India generally must submit an annual return and financial statements to the Registrar of Companies (ROC). The Companies Act, 2013 replaced the routine filing framework under the Companies Act, 1956, and introduced the MGT-7 series and AOC-4 series of forms.

Important: The older Forms 20B, 21A, 23AC, 23ACA and 66 discussed under the Companies Act, 1956 are historical forms, not the standard annual filing forms for current financial years. The applicable form, attachments and due date depend on the company category and current MCA notifications.

ROC annual filing: forms and statutory deadlines

Compliance	Form	General filing deadline	Legal basis
Annual return	MGT-7; MGT-7A for OPCs and small companies	Within 60 days of the AGM; where no AGM is held, within 60 days of the date on which it should have been held, with reasons	Section 92(4); Management and Administration Rules
Financial statements and associated documents	AOC-4 or applicable variant, including AOC-4 XBRL / AOC-4 CFS	Generally within 30 days of the AGM; separate rules apply to OPCs and certain other categories	Section 137; Companies (Accounts) Rules
Auditor appointment intimation, where applicable	ADT-1	Generally within 15 days of the relevant appointment meeting	Section 139 and Audit and Auditors Rules

1. Annual return under Section 92: MGT-7 and MGT-7A

Section 92 requires a company to prepare an annual return containing prescribed particulars as at the close of the financial year. These include registered-office and principal business details, share capital or membership, directors and key managerial personnel, meetings, remuneration and other disclosures as applicable.

Form MGT-7 is generally used by companies other than one person companies (OPCs) and small companies. Form MGT-7A is the abridged annual return prescribed for OPCs and small companies. A company without share capital must report the relevant membership information in its applicable current return rather than use historical Form 21A.

Under Section 92(4), the annual return is ordinarily filed within 60 days of the AGM. The return is signed in accordance with Section 92 and the applicable rules. Certification by a practising company secretary in Form MGT-8 is required for listed companies and other prescribed classes under Rule 11(2), including companies meeting the applicable paid-up share capital or turnover thresholds.

2. Financial statements under Sections 129, 134 and 137: AOC-4

Section 129 governs preparation and presentation of financial statements; Section 134 addresses Board approval, signing and the Board's report; and Section 137 requires filing with the ROC. Financial statements ordinarily include the balance sheet, statement of profit and loss, notes and other statements required for the relevant company.

File the appropriate AOC-4 form within 30 days of the AGM in the ordinary case. Where applicable, consolidated financial statements are filed through AOC-4 CFS, and companies covered by XBRL requirements use the prescribed XBRL form. Attachments may include audited financial statements, the auditor's report, Board's report and other documents specified in the current form and rules.

An OPC generally files its financial statements within 180 days of the closure of the financial year under Section 137(1), and is not required to hold an AGM. Producer companies have a special financial-statement filing timeline under Section 378ZA(10); consult the current MCA instructions.

3. Annual general meeting under Section 96

Section 96 generally requires companies other than OPCs to hold an AGM each year. The first AGM must be held within nine months from the end of the first financial year. Subsequent AGMs must ordinarily be held within six months from the end of the financial year, with no more than 15 months between successive AGMs. The Registrar may extend the time for an AGM other than the first by up to three months for special reasons.

For a company with a 31 March year-end, the ordinary AGM deadline is typically 30 September, subject to statutory exceptions and valid extensions. Filing deadlines must be calculated from the actual AGM date or the special statutory rule that applies.

4. Earlier Companies Act, 1956 forms and their present position

Under the previous legal framework, Section 159 and Form 20B dealt with annual returns of companies with share capital; Section 160 and Form 21A covered annual returns of companies without share capital. Section 220 and Forms 23AC and 23ACA covered the filing of balance sheets and profit and loss accounts. Section 383A and Form 66 related to compliance certificates for specified companies.

These provisions remain useful when examining older filing years, historical records or legacy defaults. For contemporary annual compliance, use the Companies Act, 2013, its rules and the MCA's current electronic filing forms. A separate routine annual Form 66 filing is not part of the modern framework; specific secretarial audit and certification obligations may apply under Sections 204 and 92 and their rules.

5. Practical ROC annual filing checklist

Confirm company classification, financial year, AGM requirements and applicable statutory exemptions.
Finalize books of account, financial statements, statutory audit and Board approval as applicable.
Issue AGM notices, conduct the AGM where required and record resolutions and minutes.
Prepare the annual return, directors' and members' particulars, and share transfer details where applicable.
Select the current MCA V3 version of MGT-7/MGT-7A and AOC-4 or the appropriate variant; complete prescribed attachments and digital signatures.
Submit filings on the MCA portal, pay the applicable fees and retain the acknowledgement and SRN.

6. Late filing, additional fees and penalties

Failure to file the annual return can attract consequences under Section 92(5); failure to file financial statements can attract consequences under Section 137(3). Additional filing fees may also apply under Section 403 and the relevant fees rules. The amount and treatment depend on the default, applicable amendments and current MCA fee schedule. Persistent defaults may also have implications for directors under Section 164(2).

7. Official sources and updated filing guidance

Updated: 8 October 2026. This article provides general information; check the current MCA forms, notifications and company-specific requirements before filing.