ENCO Legal | Corporate & Commercial Law | 26 October 2026
Quick Answer: What Are the New AOC-4 and MGT-7 Filing Deadlines?
Under Ministry of Corporate Affairs General Circular No. 05/2026 dated 24 October 2026, specified financial-statement forms for FY 2025–26 may be filed up to 31 December 2026 without additional fees. Annual returns in MGT-7 and MGT-7A may be filed up to 31 January 2027 without additional fees. The circular does not extend the statutory deadline for holding an Annual General Meeting (AGM). Normal filing fees are not waived.
What Has MCA Announced?
The Ministry issued the circular after receiving representations concerning annual statutory filing deadlines for FY 2025–26. It grants additional-fee relief for the specifically named forms, while preserving separate AGM obligations. The circular is reproduced in this published text and corroborated by contemporary reporting.
Which forms are covered?
31 December 2026: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), and AOC-4 CFS NBFC (Ind AS). 31 January 2027: MGT-7 and MGT-7A. The relief concerns the specified forms for FY 2025–26 only.
What Is Form AOC-4?
AOC-4 is used to file financial statements and associated documents with the Registrar of Companies. Section 137 of the Companies Act, 2013 generally requires financial statements to be filed within 30 days of the AGM, subject to the Act’s special circumstances. If an AGM was held on 30 September 2026, the ordinary 30-day deadline would be 30 October 2026. The circular allows the covered filing until 31 December 2026 without additional fees.
What about One Person Companies?
An OPC is subject to special provisions: Section 137 addresses filing within 180 days of financial-year closure, rather than the ordinary AGM-based calculation. The applicable form and circular must be read together.
What Is Form MGT-7?
MGT-7 is the annual-return form under Section 92 of the Companies Act, 2013. Section 92(4) generally requires the annual return within 60 days of the AGM and also addresses cases where no AGM was held. For an AGM held on 30 September 2026, the ordinary 60-day period ends on 29 November 2026. The circular allows covered filings through 31 January 2027 without additional fees.
What is MGT-7A?
MGT-7A is an abridged annual-return form for eligible One Person Companies and small companies, subject to the applicable statutory definitions and rules.
Has MCA Extended the AGM Deadline?
No. Paragraph 3 of General Circular No. 05/2026 expressly states that it does not extend statutory AGM timelines. Section 96 generally requires an AGM within six months after financial-year end, subject to exceptions and valid extensions. For a year ending 31 March 2026, the ordinary AGM deadline was 30 September 2026. The circular does not retrospectively cure an AGM default.
What if the AGM was not held on time?
The company should assess its position separately under the Companies Act, including Section 99 where applicable. Section 92(4) and Section 137 also address filing where no AGM has been held. Failure to hold an AGM does not necessarily eliminate annual filing obligations.
Does the Extension Mean Companies Pay No Filing Fees?
No. The circular waives additional fees within the specified filing window; ordinary filing fees remain applicable. It is not a blanket waiver of statutory penalties, defaults or unrelated compliance obligations.
What Happens If a Company Files After the New Deadline?
Paragraph 4 states that filings after the relaxed window attract all applicable fees, including additional fees under the Companies (Registration Offices and Fees) Rules, 2014, calculated from the original statutory due date—not merely from 1 January or 1 February 2027.
Example: AOC-4 filed in January 2027
If a company’s original AOC-4 due date was 30 October 2026, filing after 31 December 2026 may attract additional fees counted from 30 October 2026, subject to the applicable fee rules.
Example: MGT-7 filed after 31 January 2027
Where the original annual-return deadline was 29 November 2026, filing after the relaxed date may result in additional fees calculated from the original deadline. Companies should avoid assuming the relaxation permanently resets the statutory clock.
Does the MCA Extension Apply to LLPs?
The circular identifies company forms under the Companies Act, 2013. It does not expressly extend LLP Form 8 or LLP Form 11 deadlines. LLP compliance is governed by a separate framework.
Does It Cover ADT-1, MGT-14, Income Tax or GST?
No such relaxation is specified for ADT-1 or MGT-14, and the MCA circular does not change deadlines under income-tax or GST law. Each filing must be assessed under its own governing provisions and notifications.
What Should Company Directors Do Now?
1. Verify AGM compliance
Check whether the AGM was held within the applicable period, and assess any missed deadline separately.
2. Finalise financial statements
Complete the financial statements, board approvals, auditor reports and applicable supporting documents.
3. Confirm the correct AOC-4 variant
Check whether the company requires standard, consolidated, XBRL or an applicable NBFC form.
4. Prepare MGT-7 or MGT-7A
Reconcile statutory registers, corporate information and the prescribed annual-return disclosures.
5. Check digital signatures and authorisations
Verify valid DSCs, filing credentials and approvals.
6. Review unrelated filings
Check auditor-appointment, resolution, LLP, tax and other obligations independently.
7. File early and preserve evidence
Avoid last-day filing risks. Keep acknowledgements, payment receipts, copies of forms and supporting documents.
What If the Company Has Already Filed?
Retain the acknowledgement and verify filing status. The circular does not expressly establish a general refund mechanism for additional fees already paid; any such entitlement requires an applicable provision or subsequent official clarification.
Frequently Asked Questions
What is the new AOC-4 due date for FY 2025–26?
31 December 2026 for the covered AOC-4 forms.
What is the new MGT-7 due date?
31 January 2027.
Is MGT-7A covered?
Yes, expressly.
Are XBRL filings covered?
Yes, AOC-4 (XBRL) is listed.
Are consolidated financial statements covered?
Yes, the circular identifies AOC-4 (CFS) and the relevant NBFC consolidated form.
Has the AGM deadline been extended?
No. Paragraph 3 expressly preserves the statutory AGM deadline.
Does the relief apply to private limited companies?
It applies to eligible companies filing the specified forms for FY 2025–26, subject to applicable law.
Are ordinary filing fees waived?
No. The relief concerns additional fees.
What if AOC-4 is filed in January 2027?
Applicable additional fees may be calculated from the original statutory due date.
Is LLP Form 8 covered?
No such extension is provided by this circular.
Is ADT-1 covered?
No such extension is specified.
Does filing within the relaxed period cure an AGM default?
No.
Does the circular cover earlier financial years?
It specifically addresses FY 2025–26.
Where can the circular be verified?
Consult the Ministry of Corporate Affairs circulars section for General Circular No. 05/2026 dated 24 October 2026.
Conclusion
MCA General Circular No. 05/2026 gives companies additional time to file specified financial statements through 31 December 2026 and annual returns through 31 January 2027 without additional fees. It does not extend AGMs, waive all statutory penalties or cover unrelated forms. The key compliance principle is to distinguish filing-fee relief from other obligations under the Companies Act.
Legal Authorities and Sources
Ministry of Corporate Affairs, General Circular No. 05/2026 dated 24 October 2026 (reproduced circular text); Companies Act, 2013, Sections 92, 96, 99 and 137 (India Code); Companies (Registration Offices and Fees) Rules, 2014; Business Standard, 24 October 2026; Professional analysis, 25 October 2026.
Source-Verification Qualification
The circular’s operative dates and qualifications were checked against a reproduced text and contemporary reporting. The original MCA-hosted circular PDF was not independently downloaded during preparation. Subsequent official clarifications, if any, should be checked.
Legal Disclaimer
This article is solely for general legal information and education. It does not constitute legal advice, an invitation to engage legal services or an advocate-client relationship. Corporate compliance obligations depend on applicable law, rules, notifications and individual circumstances. No legal or regulatory outcome is guaranteed.
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