MCA Extends Annual Filing Due Dates for FY 2025-26: AOC-4 by 31 December 2026 and MGT-7 by 31 January 2027

The Ministry of Corporate Affairs (MCA) has extended the timelines for filing annual financial statements and annual returns for the financial year 2025-26, allowing companies additional time to complete these compliances without payment of additional fees. The relief is provided under MCA General Circular No. 05/2026 dated 24 October 2026.

1. Revised Due Dates for Annual Filings

As per the circular, companies can file the following statutory forms within the extended timelines without additional fees:

• Financial statements – 31 December 2026: The extension covers Forms AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS), as applicable.

• Annual returns – 31 January 2027: The extension covers Forms MGT-7 and MGT-7A, as applicable.

These extensions apply to annual filings for FY 2025-26. Companies must select the appropriate form based on their legal status and applicable reporting requirements.

2. No Additional Fees Within the Extended Period

Companies filing the specified forms within the extended dates will not be required to pay additional filing fees. However, the relaxation relates to additional fees and should not be interpreted as a complete waiver of the normal statutory filing fee.

The extension provides companies with additional time to finalise audited financial statements, complete the necessary approvals and reconcile the information required for annual filings.

3. AGM Due Dates Remain Unchanged

An important clarification in the circular is that the extension applies only to the specified annual filing forms. It does not extend the statutory timeline for holding an Annual General Meeting (AGM).

Under Section 96 of the Companies Act, 2013, companies are generally required to hold their AGM within six months from the end of the financial year, subject to applicable statutory provisions and exceptions.

Therefore, companies that failed to hold their AGM within the prescribed period remain liable under the relevant provisions of the Act. The filing extension does not automatically regularise an AGM default or remove the associated legal consequences.

4. Additional Fees After the Extended Due Dates

Companies should carefully monitor the revised deadlines to avoid further compliance costs.

As clarified in paragraph 4 of MCA General Circular No. 05/2026, filings made after the extended period will attract applicable filing fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014.

Importantly, such additional fees will be calculated from the original statutory due date applicable to the filing, rather than from the extended date granted under the circular. Accordingly, companies should not assume that missing the extended deadline will result in additional fees being calculated only from December 2026 or January 2027.

5. Recommended Actions for Companies

To make the most of this extension, companies should:

• Finalise and obtain the necessary approvals for their financial statements.

• Identify the applicable AOC-4 variant and ensure that the required attachments and disclosures are complete.

• Prepare and verify the annual return in Form MGT-7 or MGT-7A, as applicable.

• Confirm that AGM requirements have been met independently of the filing extension.

• Complete the filings well before the revised deadlines to reduce the risk of last-minute errors or technical difficulties.

Companies should also remember that this circular specifically covers the listed financial statement and annual return forms for FY 2025-26. Other statutory filings should continue to be completed within their respective applicable timelines unless separate relief is announced.

Conclusion

MCA General Circular No. 05/2026 dated 24 October 2026 provides welcome relief by extending the deadline for financial statement filings to 31 December 2026 and annual return filings to 31 January 2027, without additional fees. However, the AGM timeline remains unchanged, and filings made after the extended dates will attract applicable additional fees calculated from the original due dates.

Companies should use this additional time to complete their annual compliances accurately and avoid unnecessary penalties and costs.

For expert guidance on this topic, contact your tax professional today.

Sources and References

1. Ministry of Corporate Affairs, General Circular No. 05/2026 dated 24 October 2026 — Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013.

2. Companies Act, 2013 — Sections 92, 96 and 137, relating to annual returns, Annual General Meetings and financial statement filings, respectively.

3. Companies (Registration Offices and Fees) Rules, 2014 — applicable filing fees and additional fees.

 Learn the revised dates and AGM compliance requirements. Consult your CA today.