ROC annual filing for FY 2025-26: the AOC-4 and MGT-7 checklist, and the messages to send company clients

This year the ROC dates sit right on top of the tax dates. The tax audit report is due by 21 October and AOC-4 by 30 October; returns for audit cases are due by 21 November and MGT-7 by 29 November. Ask company clients for everything both forms need straight after the AGM, while the year's papers are still on their desk, and November does not become a second round of chasing.

The dates for FY 2025-26

• The AGM is held within six months of the end of the financial year, so by 30 September 2026. A company's first AGM can be held within nine months, and the ROC can extend any other AGM by up to three months.¹
• AOC-4, the financial statements as adopted at the AGM, is filed within 30 days of the AGM: by 30 October 2026 for an AGM on 30 September.¹
• MGT-7, the annual return, is filed within 60 days of the AGM: by 29 November 2026 for an AGM on 30 September.¹ Small companies and One Person Companies file MGT-7A, the abridged annual return.⁶
• If the AGM was held on another date, or the ROC extended it, count the 30 and 60 days from the day it was actually held. If no AGM was held, both are due within 30 and 60 days of the last date it should have been held, with a statement of the reasons.¹
• One Person Companies file AOC-4 within 180 days of the end of the financial year, so for 2025-26 that date, 27 September 2026, has passed.¹

The tax dates around them come from CBDT Circular No. 07/2026, which moved the return for audit cases to 21 November 2026 and, with it, the tax audit report to 21 October 2026.⁸ The rest of the half-year's dates are in our compliance calendar.

No extension this year, so far

For FY 2024-25, MCA let companies file AOC-4 and MGT-7 without additional fees past the due dates, first by General Circular No. 06/2025 of 17 October 2025, and then up to 31 January 2026 by General Circular No. 08/2025.⁵ For FY 2025-26 there is nothing yet: on 17 October 2026, the latest circulars on MCA's site were job notices from early October, and the last one on company filings was No. 4/2026, which extended the Companies Compliance Facilitation Scheme, 2026 to 15 September 2026.⁴ Our suggestion: tell clients 30 October, and treat any relief as a bonus.

What a late form costs

A form filed after its due date carries an additional fee of ₹100 for every day of delay, for AOC-4 and MGT-7 separately, on top of the normal filing fee.³ An AOC-4 filed a month late costs ₹3,000 more, and the matching MGT-7 the same again.

The fee is not the only cost. Under sections 137(3) and 92(5), the company can be penalised ₹10,000, plus ₹100 for each day the failure continues, up to ₹2 lakh. Officers in default face ₹10,000 plus ₹100 a day, up to ₹50,000 each. For AOC-4, that means the managing director and the CFO, or a director the board has made responsible, or else every director.²

What to collect from each company client

AOC-4 carries the financial statements with the documents the Act attaches to them: the auditor's report and the board's report.¹ The annual return is about the year itself: the shareholding and who joined or left it, the directors and key managerial personnel and any changes, the meetings held with attendance, and what directors were paid.¹ So one list covers both forms.

Our recommendation: send this one list the day after the AGM, even though MGT-7 is due a month after AOC-4. The client's office has just pulled out the year's registers and minutes for the meeting. Asking for them again in November means asking in the same week as the 21 November returns. MCA also advises that the signing director's DSC be linked to their user ID on its new portal,⁷ and an expired or unlinked DSC is a problem you want to find in October, not on the 29th.

Messages you can copy

Replace the words in brackets, and write them in English or Hindi, whichever your clients use. Set your own cut-off about a week before 30 October, as in our GST reminders.

The documents for the tax audit go out in the same weeks, and that list is in our ITR documents checklist. Once the filings are done, our fee reminder templates cover collecting your own fee.

What can run by itself

• The list, sent to each company client the day after its AGM date, with both due dates worked out from that date.
• A tracker of what each company has sent for AOC-4 and for the annual return, updated as files arrive.
• Follow-ups that name only the missing items, go only to clients with something pending, and stop once the set is complete. This is how our client reminders work.
• Sorting the files as they arrive, so the signed accounts, the board's report and the registers land in each company's folder, as in our document processing.

What stays with your team

• The forms. Filling, checking, certifying and filing them, and replying to any resubmission request from the ROC.
• Judgment calls. Whether a company qualifies as a small company for MGT-7A, and what to do about a meeting or a change that was never recorded properly.
• The director who travels. Getting a signature, or a renewed DSC, from the one person who has to give it.

If MCA does extend the dates

An extension, if one comes, will appear on MCA's circulars page, as last year's did. It changes the date you tell clients, not the list you send them, and we will update this article if it happens. Until then, plan for 30 October and 29 November. More of what we write for CA practices is on the blog.

Questions CAs ask