AOC-4 Due 30 October 2026: 6 Days Left, No Extension Circular Yet — Annual Filing Checklist

If your company held its AGM on 30 September 2026, the MCA annual-filing clock is already ticking loudly. The auditor-appointment form (ADT-1) was due on 15 October and is already running late fees. AOC-4 is 6 days away. And a widely-shared “extension” rumour is tempting directors to wait. Here’s the honest picture: wait only if you enjoy paying ₹100 a day.

This is the deadline-driven companion to our compliance calendar hub, which tracks every GST, income-tax and MCA due date in one place.

The extension question: what ICSI asked vs what exists

On 9 October 2026, the Institute of Company Secretaries of India (ICSI) wrote to the Ministry of Corporate Affairs asking that the due dates for annual filing forms — including AOC-4 and MGT-7 — be extended to 31 December 2026 without additional fees for FY 2025-26.

That letter is a representation, not an extension. As on 24 October 2026, MCA has not issued any numbered General Circular extending the dates. Only such a circular can waive additional fees — a request cannot. This is the single most important fact in this article: your deadlines have not moved.

Could a circular still come? Possibly — MCA has waived fees before when its own portal caused the problem. But planning on it is a one-sided bet: filing AOC-4 by 30 October costs nothing extra, while waiting costs ₹100 per day per form with no cap if no circular comes. File on the statutory dates. If relief is announced, you lose nothing.

Your deadlines (AGM held 30 September 2026)

Two fine-print notes. First, AOC-4 has variants: listed companies and unlisted public companies with paid-up capital of ₹5 crore or more (or turnover of ₹100 crore or more) file AOC-4 XBRL, and companies preparing consolidated statements file AOC-4 CFS — all on the same 30-day clock. Second, MGT-7A is the simplified form for One Person Companies and small companies; everyone else files MGT-7.

And if your AGM was not on 30 September, count forward from your actual AGM date: 30 days for AOC-4, 60 days for MGT-7. The table above is the common case, not a substitute for your own calendar.

What a day of delay actually costs

Additional fees run at ₹100 per day, per form, under Rule 12 of the Companies (Registration Offices and Fees) Rules, 2014 — with no upper cap. A 30-day delay on two forms is ₹6,000. Here’s a realistic worked example:

A private limited company held its AGM on 30 September 2026 but filed both forms only on 14 February 2027:

• AOC-4: due 30 Oct 2026 → filed 14 Feb 2027 = 107 days late → ₹100 × 107 = ₹10,700
• MGT-7: due 29 Nov 2026 → filed 14 Feb 2027 = 77 days late → ₹100 × 77 = ₹7,700
• Total additional fees: ₹18,400 — before the base government filing fees.

If the same company also missed DIR-3 KYC for two directors (₹5,000 per director to reactivate), add ₹10,000 more. And here’s the part that stings: a deactivated DIN blocks all MCA filings for the entity — so the KYC miss can delay the AOC-4 itself, stacking the meters. A small company’s avoidable outflow in this scenario: roughly ₹28,400. Our director KYC guide explains the current KYC cycle.

The file-now checklist

Gather these before you log in to MCA V3 — last-day scrambles fail on missing documents, not on the form itself:

1. Corporate documents: audited financial statements for FY 2025-26 (signed by the board and auditor), Board’s Report, Auditor’s Report, and minutes of all board meetings and the AGM.
2. Shareholder and director data: updated Register of Members, MBP-1 declarations from directors, DIN and PAN of every director/KMP, and a working DSC token or e-sign credential for the signing director.
3. MCA master reconciliation: a screenshot of the company master data on MCA V3 (registered office, authorised and paid-up capital, email) and any charge creation/satisfaction records from the year.
4. Tax and statutory data: DPT-3 acknowledgement (it was due 30 June 2026), DIR-3 KYC acknowledgements for all directors, and a PAN-linked email and mobile for OTP authentication.
5. MSME-1 data: if you owe any MSME-registered supplier beyond 45 days, the half-yearly MSME-1 is due 31 October — see our explainer on the 45-day MSME payment rule for why this one has income-tax consequences too.

MCA V3 portal gotchas

The most common cause of last-day missed filings isn’t procrastination — it’s technical failure: PAN mismatches, expired DSCs, and portal congestion in the final 48 hours. Start every filing at least two calendar weeks before the statutory due date, verify PAN, DIN and DSC status first, and keep the SRN of every submitted form. MCA V3 is better than its predecessor, but the last week of October is still its heaviest load of the year.

FAQs

Has MCA extended the AOC-4/MGT-7 due dates for FY 2025-26?

Not as of 24 October 2026. ICSI requested an extension to 31 December 2026 on 9 October 2026, but no MCA circular has been issued. File on the statutory dates.

Is the due date 29 or 30 October for AOC-4?

Section 137 says “within thirty days of the date of the AGM” — the AGM day itself counts, which is why MCA’s own form help shows 29 October for a 30 September AGM in some references while most practitioners use 30 October. File by 29 October and the argument disappears entirely.

What’s the difference between MGT-7 and MGT-7A?

MGT-7A is a simplified annual return for One Person Companies and small companies, introduced in 2021. All other companies file the full MGT-7. The 60-day deadline is the same.

Can I file AOC-4 if a director’s DIN is deactivated for missed KYC?

Effectively no — a deactivated DIN blocks the company’s MCA filings. Reactivate first (₹5,000 per DIN after the window closes), then file. This is why KYC misses cascade into filing delays.

Sources

• Institute of Company Secretaries of India — representation letter to the Ministry of Corporate Affairs dated 9 October 2026, requesting extension of annual filing forms (AOC-4, MGT-7) to 31 December 2026 without additional fees; status as on 14 October 2026 — no MCA circular issued (reported by meritfoxtech.in).
• Companies Act, 2013 — Section 137(1) (AOC-4 within 30 days of AGM), Section 92(4) (MGT-7 within 60 days of AGM), Section 139(1) (ADT-1 within 15 days of AGM).
• Companies (Registration Offices and Fees) Rules, 2014, Rule 12 — additional fee of ₹100 per day per form for delayed filing, no upper cap.
• Compliance status and worked examples cross-checked against legalsuvidha.com ROC compliance pages (updated October 2026) and corplawupdates.in (22 October 2026).