Corporate Compliance: MCA Extends Annual Filing Deadlines for FY 2025-26

In a welcome move, the Ministry of Corporate Affairs (MCA), by General Circular No. 05/2026 dated 24 October 2026, has extended the time for filing financial statements and annual returns for the financial year 2025-26, without payment of additional fees.

The key points are set out below:

1. Financial statements may be filed up to 31 December 2026, and annual returns up to 31 January 2027.
2. The relaxation applies to the following e-forms:
   • For filing financial statements:
     • AOC-4 – Form for filing financial statements and other documents with the Registrar
     • AOC-4 (CFS) – Consolidated financial statements
     • AOC-4 (XBRL) – Financial statements in XBRL format
     • AOC-4 NBFC (Ind AS) – Financial statements of NBFCs
     • AOC-4 CFS NBFC (Ind AS) – Consolidated financial statements of NBFCs
   • For filing annual returns:
     • MGT-7 – Annual return for companies other than OPCs and small companies
     • MGT-7A – Abridged annual return for OPCs and small companies
3. No additional fees will be payable on filings made within these extended timelines.

Background

On 14 July 2025, revised e-forms for these filings were deployed on the MCA-21 Version 3 portal. They formed part of the final set of 38 company forms, and their deployment completed the transition from V2 to V3. The change affected filings for FY 2024-25 (ending 31 March 2025).

Ahead of the deployment, these e-forms were unavailable from 18 June 2025 to 13 July 2025 because of a scheduled system migration. Where a due date or resubmission date fell within that period, General Circular No. 01/2025 dated 16 June 2025 extended the deadline to 15 August 2025, without additional fees.

After the new e-forms were rolled out, the MCA gave companies time to become familiar with the filing process. General Circular No. 06/2025 dated 17 October 2025 extended the deadline for FY 2024-25 annual filings to 31 December 2025, without additional fees. General Circular No. 08/2025 dated 30 December 2025 then extended it further to 31 January 2026.

For FY 2025-26: The present relaxation follows representations from stakeholders seeking more time. They cited the enhanced disclosure requirements under the revised annual filing forms and persistent portal issues, including frequent downtime and automatic logouts during filing.

Points to note:

• The circular does not extend the statutory time for holding AGMs under the Companies Act, 2013. Companies that have not met the applicable timelines remain liable under the relevant provisions of the Act.
• Filings made after the relaxation period will attract all applicable fees, including additional fees, calculated from the date on which the filings were originally due under the Act.
• The relaxation applies only to filings for FY 2025-26 and does not cover pending filings for earlier years. By contrast, the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), which closed on 15 September 2026, allowed companies to make pending filings, including those for FY 2024-25, on payment of the normal filing fees and only 10% of the applicable additional fees.