The AGM was only step one
With the statutory deadline for holding the Annual General Meeting falling on 30 September 2026 for most companies, many businesses are treating the AGM itself as the finish line. It isn’t. Once the AGM is held, two further ROC filings fall due on fixed timelines measured from the AGM date, and missing either one carries a penalty that runs every single day the form stays unfiled.
AOC-4: due within 30 days of the AGM
Form AOC-4 (or AOC-4 XBRL / AOC-4 NBFC, depending on the company) contains the financial statements, Board’s report, and auditor’s report, and must be filed with the Registrar of Companies within 30 days of the AGM. For a company that holds its AGM on 30 September 2026, this puts the AOC-4 deadline at 30 October 2026. Companies that adopted their financial statements at an adjourned AGM should count the 30 days from the adjourned date, not the original one.
MGT-7 / MGT-7A: due within 60 days of the AGM
The annual return, filed in Form MGT-7 for most companies or the simplified MGT-7A for small companies and One Person Companies, is due within 60 days of the AGM. For an AGM held on 30 September 2026, that places the MGT-7/7A deadline at 29 November 2026. This filing captures shareholding pattern, directors and KMP details, and other governance particulars as they stood at the close of the financial year.
The penalty structure is not forgiving
Unlike some compliance defaults that attract a flat late fee, delayed AOC-4 and MGT-7 filings attract a penalty of Rs 100 per day of default, with no upper cap, and it applies to the company as well as to every officer in default individually. A filing that slips by even a few weeks can add up quickly, and there is no discretion to waive it administratively once the default has occurred.
Three years of default has consequences beyond money
If a company fails to file its financial statements or annual returns for three consecutive financial years, its directors become liable for disqualification under Section 164(2) of the Companies Act, 2013, and are barred from being appointed or reappointed as directors of that company or any other company for five years. Persistent non-filing can also prompt the Registrar to initiate strike-off proceedings against the company under Section 248.
What to check before you file
Before submitting AOC-4, confirm that the financial statements match what was actually adopted at the AGM, that the auditor’s report and Board’s report are in final form, and that any XBRL tagging requirements applicable to your company have been completed correctly. For MGT-7/MGT-7A, reconcile shareholding and director details as on the financial year-end date, since mismatches are a common reason for filings needing correction later.
Plan the next 60 days now
With AOC-4 due at the 30-day mark and MGT-7 at the 60-day mark, both filings sit inside a tight window right after AGM season. Building them into your compliance calendar now, rather than after the AGM dust settles, is the simplest way to avoid the per-day penalty exposure altogether.
This post is for general informational purposes and does not constitute tax advice. Please consult us directly for guidance specific to your situation.
