MCA Extends AOC-4 and MGT-7 Due Dates for 2025-26: Financial Statements by 31 December 2026, Annual Returns by 31 January 2027, Without Additional Fees
General Circular 05/2026 of 24 October 2026 lets companies file their 2025-26 financial statements (AOC-4 and its variants) up to 31 December 2026 and annual returns (MGT-7 and MGT-7A) up to 31 January 2027 without the ₹100-a-day additional fee. The AGM date is not extended, other forms are not named, and anything filed after the new dates pays additional fees counted from the original due date.
The Ministry of Corporate Affairs has given companies more time for their annual filings for the financial year 2025-26. General Circular No. 05/2026, dated 24 October 2026, allows the financial statements to be filed up to 31 December 2026 and the annual return up to 31 January 2027, without the additional fee that normally runs at ₹100 a day. For a company that held its AGM on 30 September, that is 62 more days for AOC-4 and 63 more for MGT-7. This note sets out exactly what the circular covers, what it leaves out, and what a late filing will cost after the new dates.
Written on 25 October 2026 from the text of General Circular No. 05/2026 (File No. Policy-17/111/2022-CL-V-MCA), read on the Ministry's website, and the fee tables in MCA's instruction kit for Form AOC-4. Dates for your company depend on when its AGM was held; the examples assume an AGM on 30 September 2026. This explains the circular; it is not advice on any company's filings.
05/2026 — General Circular dated 24 October 2026 · 31 Dec 2026 — AOC-4 and its variants for 2025-26 · 31 Jan 2027 — MGT-7 and MGT-7A for 2025-26 · ₹0 — additional fee if filed by those dates · ₹100 a day — additional fee after them, counted from the original due date
What the circular allows
The Ministry says it received representations asking for more time for the annual statutory forms under the Companies Act, 2013 for 2025-26. Paragraph 2 of the circular allows companies to file the following without payment of additional fees:
| Form | What it files | New last date without additional fee |
|---|---|---|
| AOC-4 | Financial statements and attached documents | 31 December 2026 |
| AOC-4 (CFS) | Consolidated financial statements | 31 December 2026 |
| AOC-4 (XBRL) | Financial statements in XBRL, for companies required to use it | 31 December 2026 |
| AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) | Financial statements of NBFCs following Ind AS, standalone and consolidated | 31 December 2026 |
| MGT-7 | Annual return | 31 January 2027 |
| MGT-7A | Annual return of one person companies and small companies | 31 January 2027 |
The relief applies only to filings for the financial year 2025-26. The normal filing fee still applies; what is waived is the additional fee for delay.
Original due dates and the relaxed dates
Under the Companies Act, a company's AGM for 2025-26 had to be held by 30 September 2026 (section 96). AOC-4 is due within 30 days of the AGM (section 137(1)) and MGT-7 or MGT-7A within 60 days of it (section 92(4)). A one person company holds no AGM and files AOC-4 within 180 days of the year end.
| Company | Form | Original due date | Relaxed date | Extra time |
|---|---|---|---|---|
| AGM on 30 September 2026 | AOC-4 | 30 October 2026 | 31 December 2026 | 62 days |
| AGM on 30 September 2026 | MGT-7 / MGT-7A | 29 November 2026 | 31 January 2027 | 63 days |
| AGM held earlier, say 10 September 2026 | AOC-4 | 10 October 2026 (already passed) | 31 December 2026 | Not yet filed: no additional fee if filed by 31 December |
| One person company | AOC-4 | 27 September 2026 (180 days from 31 March) | 31 December 2026 | Covered on the circular's plain words, which refer to "companies" without exception |
A company whose original date has already passed and which has not yet filed benefits from the relaxation, because the circular waives the additional fee for any filing made up to the new dates. A company that has already filed late and paid additional fees gets nothing back: the circular is silent on refunds.
What the circular does not extend
The AGM. Paragraph 3 is explicit: the circular "shall not be construed as conferring any extension of statutory time for holding of AGMs", and companies that have not met the statutory timelines remain liable under the Act. A company that missed its 30 September AGM without an extension from the Registrar is in default for the AGM, whatever date it files AOC-4 on.
Other forms. Only the AOC-4 family, MGT-7 and MGT-7A are named. The circular does not mention:
- ADT-1, the notice of the auditor's appointment, due within 15 days of the AGM at which the auditor is appointed (section 139(1));
- MGT-14, for resolutions that must be filed within 30 days of being passed (section 117), such as a board resolution approving the financial statements where it applies;
- cost audit reports, deposit returns or any other Companies Act form;
- LLP forms, such as Form 8 and Form 11, which fall under the LLP Act, not the Companies Act.
These keep their usual dates and fees.
If you file after the new dates: the fee
Paragraph 4 of the circular closes the door on late filers. Any filing after the relaxation "would attract payment of all fees, including additional fees" under the Companies (Registration Offices and Fees) Rules, 2014, "from the date when such filings were actually due under the Act". So missing 31 December by a few days costs the whole period from the original due date, not just the days after 31 December.
| Nominal share capital | Normal fee per form |
|---|---|
| Less than ₹1 lakh | ₹200 |
| ₹1 lakh to ₹4,99,999 | ₹300 |
| ₹5 lakh to ₹24,99,999 | ₹400 |
| ₹25 lakh to ₹99,99,999 | ₹500 |
| ₹1 crore or more | ₹600 |
| Company without share capital | ₹200 |
On top of the normal fee, the additional fee for delay beyond section 137(1) (AOC-4) or section 92(4) (MGT-7) is ₹100 a day for each form, with no upper limit in the fee table.
Worked examples for an AGM on the last permitted day
| Filing | Filed on | Days counted | Additional fee |
|---|---|---|---|
| AOC-4 | 31 December 2026 | Within the relaxation | Nil |
| AOC-4 | 15 January 2027 | 77 days from 30 October | ₹7,700 |
| MGT-7 | 31 January 2027 | Within the relaxation | Nil |
| MGT-7 | 10 February 2027 | 73 days from 29 November | ₹7,300 |
A company that files both forms two weeks after the relaxed dates pays about ₹15,000 in additional fees, instead of nothing. The fees are separate from any penalty proceedings for the default itself.
What companies should do now
| Step | Why |
|---|---|
| Confirm the AGM date, or the Registrar's extension, in the minutes | The AOC-4 and MGT-7 forms ask for it, and the circular does not cure a missed AGM |
| File ADT-1 and any MGT-14 now if still pending | They are outside the circular and their fees keep running |
| Plan AOC-4 for early December, not 31 December | Attachments, the auditor's report, digital signatures and the portal's year-end load all take time; a rejected form filed on the last day may not be fixed in time |
| File MGT-7 or MGT-7A after AOC-4 | The annual return draws on the same year's figures; keep a margin before 31 January |
| Note the dates in your calendar | Our compliance calendar now shows the relaxed dates and can be added to a phone |
Frequently Asked Questions
What is the last date for filing AOC-4 for 2025-26? 31 December 2026, without additional fees, under MCA General Circular No. 05/2026. This covers AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS).
What is the last date for filing MGT-7 and MGT-7A for 2025-26? 31 January 2027, without additional fees, under the same circular.
Has the AGM date been extended? No. The circular states that it does not extend the statutory time for holding AGMs, and companies that missed it remain liable under the Act.
Is ADT-1 covered by the extension? No. The circular names only the AOC-4 forms, MGT-7 and MGT-7A. ADT-1 is still due within 15 days of the AGM.
What if a company files AOC-4 after 31 December 2026? It pays the normal fee plus ₹100 a day of additional fee, counted from the original due date. For an AGM on 30 September, filing on 15 January 2027 costs ₹7,700 in additional fees.
We already filed late and paid additional fees. Can we get a refund? The circular does not provide for one. It waives additional fees on filings made up to the new dates; it says nothing about fees already paid.
Does the extension apply to one person companies and small companies? Yes, on the circular's wording. MGT-7A, the annual return form for one person companies and small companies, is named, and the AOC-4 relaxation refers to companies generally.
Does it apply to LLPs? No. The circular is issued under the Companies Act, 2013 and covers company forms only. LLP Form 8 and Form 11 keep their usual dates.
Where can the circular be read? On the Ministry of Corporate Affairs website, as General Circular No. 05/2026 dated 24 October 2026; the link is in the sources below.
Sources
The rules and figures in this article can be checked against these official sources.
- General Circular No. 05/2026, 24 October 2026: relaxation of additional fees and extension of time for filing financial statements and annual returns for 2025-26 (File No. Policy-17/111/2022-CL-V-MCA) Ministry of Corporate Affairs
- Instruction kit for web form AOC-4: due dates, normal fees by nominal share capital and the ₹100-a-day additional fee Ministry of Corporate Affairs
- Annual filing e-forms: AOC-4 and its variants, MGT-7 and MGT-7A Ministry of Corporate Affairs
- Companies Act, 2013: sections 92 (annual return), 96 (AGM), 117 (resolutions), 137 (financial statements) and 139 (auditors) Ministry of Corporate Affairs