ROC Annual Filings: AOC-4, MGT-7 and the Daily Penalty for Delay
Akash Kore
· Founder & Product Architect· 3 min read
Company annual filings are among the few compliance obligations with an uncapped daily penalty. A form forgotten for a year costs thirty-six thousand five hundred rupees, and the liability attaches to the directors as well as the company.
- ✓AOC-4 files the financial statements within thirty days of the AGM.
- ✓MGT-7 files the annual return within sixty days of the AGM.
- ✓Late filing attracts ₹100 per day per form, with no cap.
- ✓Small companies and OPCs file MGT-7A instead.
The two forms
Form AOC-4 files the financial statements, including the balance sheet, profit and loss account, directors' report and auditor's report. It is due within thirty days of the annual general meeting.
Form MGT-7 files the annual return, covering shareholding, directors, meetings and changes during the year. It is due within sixty days of the AGM. Small companies and one-person companies file the abridged MGT-7A.
The AGM itself
A company must hold its AGM within six months of the end of the financial year, and not more than fifteen months after the previous one. For a 31 March year end, the AGM must therefore be held by 30 September.
That fixes the filing dates in most cases at 30 October for AOC-4 and 29 November for MGT-7. A one-person company is exempt from holding an AGM but still files AOC-4.
The penalty
One hundred rupees per day per form, with no maximum. There is no cap and no reduction for small companies.
Additional penalties apply to the company and to officers in default under Sections 92 and 137, and persistent default can lead to directors being disqualified under Section 164(2) for five years.
The other forms that catch people
1. DIR-3 KYC: annual KYC for every director holding a DIN, due by 30 September. A missed filing deactivates the DIN.
2. ADT-1: appointment of auditor, within fifteen days of the AGM at which they were appointed.
3. DPT-3: annual return of deposits and amounts not considered deposits, by 30 June.
4. MSME-1: half-yearly return of outstanding payments to micro and small suppliers exceeding forty-five days.
Frequently asked questions
### What is the penalty for late ROC filing?
One hundred rupees per day per form, with no upper limit, in addition to penalties on the company and officers in default under Sections 92 and 137. Persistent default can disqualify directors for five years.
### When is AOC-4 due?
Within thirty days of the annual general meeting. For a company with a 31 March year end holding its AGM by the 30 September deadline, that generally means 30 October.
### What is MSME-1?
A half-yearly return required from companies with outstanding payments to micro and small suppliers exceeding forty-five days, reporting the amounts and the reasons for delay. It is filed for the periods ending September and March.
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Frequently Asked Questions
What is the penalty for late ROC filing?
One hundred rupees per day per form, with no upper limit, in addition to penalties on the company and officers in default under Sections 92 and 137. Persistent default can disqualify directors for five years.
When is AOC-4 due?
Within thirty days of the annual general meeting. For a company with a 31 March year end holding its AGM by the 30 September deadline, that generally means 30 October.
What is MSME-1?
A half-yearly return required from companies with outstanding payments to micro and small suppliers exceeding forty-five days, reporting the amounts and the reasons for delay. It is filed for the periods ending September and March.
Akash Kore
Founder & Product ArchitectArchitecting business document operating systems and automated billing workflows for Indian SMBs, agencies, and enterprises.