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AOC-4 and MGT-7 Deadlines Extended: New Dates, Late Fees and a Filing Checklist for FY 2025-26

MCA General Circular 05/2026 moves the AOC-4 deadline to 31 December 2026 and MGT-7 to 31 January 2027. See what is extended, what is not, how late fees work and a filing checklist.

Bismanjeet Singh

Bismanjeet Singh

Company Secretary

7 November 20267 min read
Hands holding a navy annual report folder in front of a blurred calendar and bookshelf, under the title AOC-4 & MGT-7 Deadlines Extended

If you run a company in India, your annual filings with the Registrar of Companies just got more time. On 24 October 2026, the Ministry of Corporate Affairs (MCA) issued General Circular No. 05/2026. It extends the due dates for AOC-4 (financial statements) and MGT-7 or MGT-7A (annual return) for FY 2025-26, and it waives the additional fee inside the extended window.

This guide explains the new dates, how late fees work, what the circular does not cover, and what to do now. It is based on published summaries of the circular. Please read the circular itself on the MCA website before you file.

Quick summary

  • AOC-4 and its variants can now be filed up to 31 December 2026.
  • MGT-7 and MGT-7A can now be filed up to 31 January 2027.
  • No additional fee applies if you file within these dates.
  • After the extended date, additional fees are counted from the original due date, not from the new one.
  • The circular does not extend the time for holding the AGM, and, as reported, it does not cover ADT-1.

What the circular says

According to published summaries, MCA General Circular No. 05/2026 is dated 24 October 2026. It followed a representation from the Institute of Company Secretaries of India (ICSI) dated 9 October 2026, which cited problems with the MCA21 V3 portal.

The forms covered are:

  • AOC-4
  • AOC-4 (CFS)
  • AOC-4 (XBRL)
  • AOC-4 NBFC (Ind AS)
  • AOC-4 CFS NBFC (Ind AS)
  • MGT-7 and MGT-7A (MGT-7A is the annual return for small companies and One Person Companies)

The dates

The original due dates depend on when your AGM was held. AOC-4 is due within 30 days of the AGM, and MGT-7 within 60 days of the AGM. For a company that held its AGM on 30 September 2026:

Form | Original due date | Extended date

AOC-4 and variants | 30 October 2026 | 31 December 2026

MGT-7 and MGT-7A | 29 November 2026 | 31 January 2027

If your AGM was on a different date, your original due dates will be different. The summaries we read do not explain precisely how the late-fee start date works for a company with an earlier AGM, so ask your company secretary to confirm it.

How the late fee works

  • Inside the extended window: no additional fee of ₹100 per day applies.
  • After the extended date: all applicable additional fees apply, and they are counted from the original due date.

The published examples show the effect:

  • AOC-4 filed on 1 January 2027: 63 days from 30 October 2026, which is 63 × ₹100 = ₹6,300.
  • MGT-7 filed on 5 February 2027: 68 days from 29 November 2026, which is 68 × ₹100 = ₹6,800.

The circular reportedly does not provide for refunds of fees that were already paid.

What is not extended

  • AGM deadlines. The circular does not give extra time for holding the AGM under the Companies Act.
  • ADT-1 (appointment of an auditor). It is due 15 days after the AGM, which was 15 October 2026 for a 30 September AGM. Late fees of ₹100 per day continue.
  • DIR-12 (changes in directors and key managerial personnel). Published summaries infer this because the circular does not mention it. The inference is not an express statement, so check it.
  • One Person Companies. A separate 180-day date applies to some OPC filings. The summaries we read do not show it as extended.

A filing checklist

  1. Confirm your AGM date and calculate your own original due dates.
  2. Finalise the audited financial statements and get the auditor's report signed.
  3. File ADT-1 if you have not, because it is not covered by the extension.
  4. Prepare AOC-4 early. Do not wait for 31 December. The reason for the extension was portal trouble, and the last days are likely to be busy.
  5. Check which annual return form applies. Small companies and OPCs use MGT-7A, other companies use MGT-7.
  6. Pay the filing fee and keep the SRN and the acknowledgement for your records.
  7. Read the circular on the MCA website under Acts and Rules, then Circulars, and check that your company's situation is covered.

Frequently asked questions

Is the AGM deadline also extended?

No. The circular does not give more time to hold the AGM.

I already filed AOC-4 and paid an additional fee. Will I get it back?

The summaries we read say the circular has no refund provision. Check the circular text.

What if I miss 31 December?

You pay the additional fee, counted from the original due date. For example, 63 days of fee if you file AOC-4 on 1 January 2027 for a company with a 30 September AGM.

Does the circular apply to every company?

It applies to the forms listed for FY 2025-26. Check the circular for any company types it leaves out.

This article is general information and not legal advice. Circulars can be clarified or changed, so confirm the position for your company with a company secretary.

Need help with your annual ROC filings, board resolutions or AGM? Talk to the StartupKaro team about your compliance calendar.

Sources

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Bismanjeet Singh

Bismanjeet Singh

Company Secretary

Oversees Company Law advisory, ROC compliance, statutory filings, and corporate governance, ensuring businesses meet every regulatory requirement.