MCA Extends AOC-4 & CRA-4 to 31 Dec 2026 and MGT-7 to 31 Jan 2027: 3 Costly Traps Directors Must Avoid!
In late October 2026, the Ministry of Corporate Affairs (MCA) provided corporate India with substantial relief by issuing two critical circulars:
- MCA General Circular No. 05/2026 (
File No. Policy-17/111/2022-CL-V-MCA, dated 24 October 2026) - MCA General Circular No. 06/2026 (
F. No. Policy-17/52/2020-CL-V, dated 27 October 2026)
These circulars extend the due dates for filing annual financial statements and annual returns for Financial Year 2025-26 without any additional fees. However, company directors must navigate three critical compliance traps.
1. Master ROC Filing Schedule for FY 2025-26
| MCA V3 e-Form | Purpose & Scope | Statutory Due Date (For 30 Sep AGM) | Extended Due Date With ₹0 Additional Fee |
|---|---|---|---|
Form AOC-4 / AOC-4 CFS / AOC-4 XBRL | Financial Statements, Balance Sheet, P&L, Board's Report (Section 137) | 30 October 2026 | 31 December 2026 (GC 05/2026) |
Form CRA-4 (XBRL) | Cost Audit Report (Section 148(6) & Rule 6(6)) | Within 30 days of Board receipt | 31 December 2026 (GC 06/2026) |
Form MGT-7 & Form MGT-7A | Annual Return for Companies, Small Companies & OPCs (Section 92) | 29 November 2026 | 31 January 2027 (GC 05/2026) |
Form ADT-1 | Appointment / Re-appointment of Statutory Auditor (Section 139) | 15 October 2026 (15 days from AGM) | NOT EXTENDED (Late fees apply) |
2. 3 Costly Compliance Traps Directors Must Avoid
Trap 1: The AGM Deadline Was NOT Extended!
A common misconception is that extending AOC-4 extends the deadline to hold the company's Annual General Meeting. Under Section 96(1) of the Companies Act, 2013, the statutory deadline to hold the FY 2025-26 AGM remained 30 September 2026. If your company did not hold an AGM by 30 September (and did not secure an ROC extension in Form GNL-1), the company and its officers remain liable for compounding under Section 99.
Trap 2: The Retrospective ₹100/Day Penalty Trap!
Both General Circular 05/2026 and 06/2026 contain an explicit penalty clause:
If a company fails to file AOC-4 by 31 December 2026 (or MGT-7/7A by 31 January 2027), the statutory ₹100 per day additional fee under Section 403 will be calculated retrospectively from the original statutory due date (i.e., from 30 October 2026 or 29 November 2026). Missing the deadline by just one day results in an instant ₹6,200+ penalty per form on 1 January 2027!
Trap 3: Form ADT-1 and LLP Filings Are Excluded!
The fee waiver applies only to the specific corporate forms listed. Filing Form ADT-1 (auditor appointment), Form PAS-6 (half-yearly unlisted share reconciliation), or LLP returns (Form 11 / Form 8) outside their statutory windows will incur regular additional fees.
3. Practical Action Plan for Private Limited Companies
- Conduct Board Review Immediately: Finalize your audited financial statements, Director's Report, and AOC-2 disclosures in November.
- Tag XBRL Early: For companies subject to mandatory XBRL filing, complete taxonomy validation early to prevent portal bottlenecks during December.
- File AOC-4 and MGT-7 Simultaneously: Complete both filings well ahead of the year-end rush.
4. Seamless ROC Annual Filing With RegisterYourFirm
Don't risk retrospective ₹100/day penalties or MCA V3 portal crashes. At RegisterYourFirm.com, our Company Secretaries handle end-to-end annual compliances, drafting Board Reports, validating XBRL statements, and filing AOC-4 and MGT-7 with guaranteed precision. Get your company compliant today.