MCA Extends AOC-4 to 31 December 2026, MGT-7 to 31 January 2027 — No Additional Fees (Circular 05/2026)

If your company held its AGM on 30 September 2026, the MCA annual-filing clock has changed: the auditor-appointment form (ADT-1) was due on 15 October and is already running late fees, but AOC-4 variants can now be filed fee-free up to 31 December 2026 and MGT-7/MGT-7A up to 31 January 2027 under MCA General Circular No. 05/2026 dated 24 October 2026. The old advice to file AOC-4 by 30 October or pay ₹100 per day no longer holds within this fee-free window.

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 request was granted in substance by MCA General Circular No. 05/2026 dated 24 October 2026: AOC-4 variants can be filed till 31 December 2026 and MGT-7/MGT-7A till 31 January 2027 without additional fees. The statutory dates have not moved and the AGM deadline is NOT extended — this is a fee-free filing window, not a new deadline. After the window, additional fees are calculated from the original due date.

The old file-by-30-Oct-or-pay-₹100/day advice no longer holds within this window. Filing AOC-4 by 31 December 2026, or MGT-7/MGT-7A by 31 January 2027, costs no additional fee under Circular 05/2026; only filings after the window attract additional fees, calculated from the original due date.

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. Circular 05/2026 does not cover LLP Form 8 (still due 30 Oct 2026), MSME-1 (still 31 Oct 2026), ADT-1 or DIR-3 KYC.

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 — but no additional fee applies within the Circular 05/2026 fee-free window. After the window, additional fees are calculated from the original due date. A 30-day delay on two forms is ₹6,000. Here’s a realistic worked example for a filing after the window:

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 end of the fee-free window, verify PAN, DIN and DSC status first, and keep the SRN of every submitted form.

FAQs

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

Yes — MCA General Circular No. 05/2026 dated 24 October 2026: AOC-4 variants can be filed up to 31 December 2026 and MGT-7/MGT-7A up to 31 January 2027 without additional fees. The AGM deadline is not extended.

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. That is the statutory counting; under Circular 05/2026, AOC-4 can in any case be filed fee-free up to 31 December 2026.

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

• MCA General Circular No. 05/2026 dated 24 October 2026 — AOC-4 variants fee-free till 31 December 2026 and MGT-7/MGT-7A fee-free till 31 January 2027, without additional fees; statutory dates and AGM deadline not extended.
• 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; granted in substance by MCA General Circular No. 05/2026 dated 24 October 2026.
• 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).