AOC-4 and MGT-7 Deadlines for FY 2025-26: Filing Without Additional Fee Until 31 December and 31 January

For FY 2025-26, companies can file their financial statements in AOC-4 up to 31 December 2026 and their annual return in MGT-7 or MGT-7A up to 31 January 2027 without paying additional fees. That is MCA General Circular No. 05/2026 of 24 October 2026. It relaxes the fee, not the law: it does not extend the time for holding the annual general meeting, and a filing made after those dates pays additional fees counted from the date it was originally due.

Sources checked: 29 October 2026

Facts checked on 29 October 2026 against MCA General Circulars No. 05/2026 and 06/2026 and the MCA instruction kits for AOC-4 and MGT-7, all read on mca.gov.in.

This is general information, not legal advice. Your own AGM date and any order of the Registrar decide your company's position.

Key facts

Point	What applies	Where it comes from
Financial statements, FY 2025-26	AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS): up to 31 December 2026 without additional fees	GC 05/2026, para 2(a)
Annual return, FY 2025-26	MGT-7 and MGT-7A: up to 31 January 2027 without additional fees	GC 05/2026, para 2(b)
AGM	Not extended; non-compliance with the statutory timelines stays liable under the Act	GC 05/2026, para 3
Filed after those dates	All fees, including additional fees, from the date the filing was actually due under the Act	GC 05/2026, para 4
Normal time limits	AOC-4 within 30 days of the AGM; MGT-7 within 60 days	AOC-4 and MGT-7 instruction kits
Additional fee when late	₹100 per day beyond section 137(1) (AOC-4) or section 92(4) (MGT-7)	Instruction kits
Cost audit report (CRA-4)	Up to 31 December 2026 without additional fees	GC 06/2026

What does General Circular 05/2026 say?

The circular records that the Ministry received representations asking for more time for the annual filings of FY 2025-26, and that "to enable companies to complete their annual statutory filings" it has decided to allow them to file:

• the financial statements in e-forms AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) for FY 2025-26 up to 31 December 2026; and
• the annual returns in e-forms MGT-7 and MGT-7A for FY 2025-26 up to 31 January 2027,

"without payment of additional fees". The normal filing fee still applies; only the additional (delay) fee is waived within those dates.

Does it extend the AGM date?

No. Paragraph 3 is explicit: the circular "shall not be construed as conferring any extension of statutory time for holding of AGMs", and companies "which have not adhered to the relevant statutory timelines shall be liable under the relevant provisions of the Act".

So a company with a 31 March year end still had to hold its AGM within the time the Act allows, which our compliance calendar shows as 30 September, unless an extension was granted for that company. The relief is only on the fee for filing the accounts and the return afterwards. A company that has not held its AGM on time has a separate problem, and the circular does not solve it.

What are the normal deadlines?

The MCA instruction kits give the time limits the circular relaxes:

• AOC-4: under section 137 of the Companies Act 2013 read with rule 12(1) of the Companies (Accounts) Rules 2014, financial statements adopted at the AGM are filed within 30 days of the AGM. If they are not adopted at the AGM, the unadopted statements are filed within 30 days of the AGM (or of its due date, if no AGM was held), and the adopted ones within 30 days of the adjourned AGM. A One Person Company files within 180 days of the end of the financial year.
• MGT-7: under section 92 read with rule 11(1) of the Companies (Management and Administration) Rules 2014, the annual return is filed within 60 days of the AGM date, or of the calculated due date of the AGM, whichever is earlier. The MGT-7 kit covers companies other than One Person Companies and small companies; those file MGT-7A.

For a late filing outside a relaxation, both kits show an additional fee of ₹100 per day for delay beyond the period in section 137(1) (AOC-4) or section 92(4) (MGT-7), on top of the normal fee. Our guide to private limited company annual compliance sets out the full year, including ADT-1, DIR-3 KYC and DPT-3.

What happens after 31 December or 31 January?

Paragraph 4 says any filing made after the circular's dates "would attract payment of all fees, including additional fees, as provided in the Companies (Registration Offices and Fees) Rules, 2014, from the date when such filings were actually due under the Act".

That matters. A company that files AOC-4 on 5 January 2027 does not pay additional fees for five days. It pays them from its original due date, 30 days after its AGM, as if there had been no relaxation. The circular rewards filing within the window; it gives nothing to a filing just outside it.

A worked example

A private company with a 31 March year end held its AGM for FY 2025-26 on 26 September 2026. Without the circular, its AOC-4 was due within 30 days of that meeting, in late October, and its MGT-7 within 60 days, in late November; from the next day, ₹100 a day would have run on each.

Under General Circular 05/2026:

• it can file AOC-4 at any time up to 31 December 2026 and MGT-7 up to 31 January 2027 with only the normal fee;
• if it files AOC-4 on 2 January 2027, the additional fee is counted from its late-October due date, not from 31 December;
• the AGM itself was on time, so paragraph 3 does not touch it. Had the AGM been held late, the delay in holding it would remain a matter under the Act whatever the filing date.

What should a company do now?

1. Check the AGM. Confirm the AGM for FY 2025-26 was held within time, or that an extension was granted. Note the date: the forms ask for it.
2. File AOC-4 by 31 December 2026. Use the variant that fits: AOC-4, AOC-4 (CFS) for consolidated statements, AOC-4 (XBRL) where XBRL filing applies, or the NBFC (Ind AS) forms.
3. File MGT-7 or MGT-7A by 31 January 2027. MGT-7A is for One Person Companies and small companies.
4. If you have a cost audit, file CRA-4 by 31 December 2026; General Circular 06/2026 waives additional fees on it up to that date, with fees from the rule 6(6) due date after that.
5. Leave a margin. A filing that slips past the date loses the whole relaxation.

Our ROC due date tracker shows the dates for your AGM date, and the ROC late fee calculator works out the additional fee if a filing has already slipped.

Does this apply to LLPs?

No. The circular is about AOC-4 and MGT-7 under the Companies Act. An LLP files Form 11 and Form 8 under the LLP Act; our guide to LLP annual filing covers those.

Getting help

Our business setup and compliance team prepares and files AOC-4, MGT-7 and the other annual company forms. To ask our expert team about your company's filings, book a consultation.