The Companies Act, 2013 introduced a sweeping overhaul of corporate compliance for Indian companies. A decade later, the cumulative weight of annual filings, event-based forms, audit obligations, statutory registers, and board procedural requirements means that even a well-run private limited company has 30+ distinct compliance touchpoints per year. This checklist organises them into four buckets — annual, event-based, audit, and registers/meetings — with the relevant section numbers, due dates, and forms.
Bucket 1: Annual filings (recurring every year)
These four filings are non-negotiable for almost every Indian company:
| Form | Section/Rule | Purpose | Due date |
|---|---|---|---|
| AOC-4 | Section 137 | Financial statements | 30 days from AGM |
| MGT-7 / MGT-7A | Section 92 | Annual return | 60 days from AGM |
| DPT-3 | Rule 16, Acceptance of Deposits Rules | Return of deposits / loan from director | 30 June |
| DIR-3 KYC | Rule 12A, Companies (Appointment) Rules | Director KYC | 30 September |
DPT-3 is often misunderstood as "only for companies that accept public deposits". In fact, every company that has any outstanding loan or money received from directors, related parties, or non-deposits must file DPT-3 annually with details of those amounts as on 31 March. Missing DPT-3 attracts a penalty of ₹10,000 + ₹100 per day under Section 73(2)/Rule 21.
Bucket 2: Event-based filings (triggered by corporate actions)
These forms are required only when specific events occur, but the 30-day filing window is strict:
| Form | Trigger event | Section | Window |
|---|---|---|---|
| PAS-3 | Allotment of shares | Section 39 | 30 days from allotment |
| SH-7 | Change in authorised capital | Section 64 | 30 days from resolution |
| MGT-14 | Special resolution or specified board resolution | Section 117 | 30 days from passing |
| DIR-12 | Appointment, resignation, change in director particulars | Section 170 | 30 days from event |
| INC-22 | Change of registered office | Section 12 | 30 days from change |
| INC-20A | Commencement of business (new companies) | Section 10A | 180 days from incorporation |
| MSME-1 | Half-yearly return of dues to MSMEs | Section 405 | 30 April and 30 October |
Bucket 3: Audit-related filings
- ADT-1 — Appointment of auditor under Section 139(1). Filed within 15 days of the AGM at which the auditor is appointed. First-time appointment after incorporation: within 15 days of the board meeting that appointed the auditor (within 30 days of incorporation).
- ADT-3 — Resignation of auditor under Section 140(2). Filed by the resigning auditor within 30 days of resignation.
- CRA-2 — Appointment of cost auditor under Section 148, where cost audit is applicable.
- NFRA-1 — Filed by certain public companies and large private companies whose securities are listed; submits annual return on the auditor.
Bucket 4: Statutory registers and minute books
Every company must maintain the following registers at the registered office:
- MGT-1 — Register of members
- MGT-2 — Register of debenture holders / beneficial owners
- MGT-3 — Foreign register of members (where applicable)
- SH-2 — Register of renewed and duplicate share certificates
- SH-3 — Register of sweat equity shares
- SH-6 — Register of employee stock options
- SH-10 — Register of shares/securities bought back
- CHG-7 — Register of charges
- MBP-2 — Register of loans/guarantees/investments under Section 186
- MBP-3 — Register of contracts with related parties under Section 189
- MBP-4 — Register of directors' interests
Plus minute books for board meetings, general meetings, and committee meetings under Section 118.
Board meeting cadence and SS-1/SS-2
Section 173 requires the board of every company (other than OPC, small company, dormant company, or private company with paid-up capital below ₹100 crore) to hold at least 4 board meetings per year, with a gap of no more than 120 days between two consecutive meetings. OPCs, small companies, and certain private companies need hold only 2 meetings per year, one in each half.
For SS-1 compliance (the procedural standard), each board meeting must have:
- 7-day notice with agenda
- Proper quorum (one-third or 2 directors, whichever is higher)
- Draft minutes circulated within 15 days
- Final signed minutes within 30 days
An annual general meeting (AGM) is mandatory for every company (other than OPC) under Section 96, by 30 September of the following calendar year, except the first AGM (which can be held within 9 months of the first FY end).
Penalties under Section 450
Section 450 is the residual penalty section — "if no specific penalty is provided". It imposes a penalty of ₹10,000 on the company and ₹10,000 on every officer in default, with a continuing penalty of ₹1,000 per day (capped at ₹2 lakh for company and ₹50,000 for officers). Many minor procedural breaches default to Section 450.
Several specific sections carry their own penalty. The compounding fees and additional fees on MCA V3 also escalate dramatically: late filing fees can be 12x the normal fees if delayed beyond a year.
Month-by-month calendar (for FY ending 31 March)
| Month | Key filings / events |
|---|---|
| April | Q4 board meeting if not yet held; MSME-1 for the half-year Oct–Mar (due 30 April) |
| May | Audit finalisation; ADT-1 review |
| June | DPT-3 (due 30 June); Form 64A for AIFs (due 15 June) |
| July | Form 64B issuance to AIF investors (by 30 June, slightly earlier) |
| September | AGM (by 30 September); DIR-3 KYC (by 30 September); ITR for non-audit cases |
| October | AOC-4 within 30 days of AGM (typically by 30 October); ITR for audit cases; MSME-1 for half-year Apr–Sep (due 30 October) |
| November | MGT-7 within 60 days of AGM (typically by 29 November) |
| December | Q2 board meeting if not done |
| January | Tax planning; advance tax for Q3 |
| February | Pre-FY-end board strategy meeting |
| March | FY closing; books closure; statutory register update |
How Kapitalyze helps
Kapitalyze tracks every annual, event-based, and registers-related compliance item for every company in your portfolio. Compliance dashboard shows a real-time RAG status of all 30+ filings, with auto-alerts 60, 30, 15, 7, and 1 day before each due date.
The platform maintains all statutory registers in digital form, updated automatically from cap table actions, board meeting outcomes, and event filings. The compliance calendar generates a personalised 12-month forward view for each company.
For CA/CS firms managing multiple clients, the CA/CS portal consolidates compliance status across all clients into a single dashboard. You can identify which clients are at risk, batch-generate filings, and bill clients automatically.
Frequently Asked Questions
Are small companies exempt from any of these filings?
Small companies (paid-up capital ≤ ₹4 crore and turnover ≤ ₹40 crore) get certain relaxations: only 2 board meetings per year required, simpler MGT-7A instead of MGT-7, and lower applicability of CARO. But annual filings (AOC-4, MGT-7A, DPT-3, DIR-3 KYC) remain mandatory.
Is a dormant company exempt from compliance?
A dormant company under Section 455 has reduced compliance: only MSC-3 (annual return of dormant company), and the board need meet only once per half-year. But MGT-7 is still required.
What if a private company has no transactions during the year?
All filings still apply. A company with zero turnover still files AOC-4 (showing nil revenue), MGT-7 (showing existing shareholding), DPT-3 (showing nil deposits), and DIR-3 KYC for each director.
Can a director sign forms for multiple companies?
Yes, as long as the director's DSC is registered with the MCA. There is no limit on the number of companies for which a single DSC can be used.
What is the fastest way to recover from missed filings?
File the overdue forms immediately along with additional fees (up to 12x normal). For older defaults that have triggered show-cause notices, apply for compounding under Section 441 — typically 50–100% of the maximum statutory penalty, but it closes the matter.
How event-based timelines actually work
Event-based filings are where most private companies trip up. The 30-day clock is unforgiving and starts on the date the corporate action occurs, not when the company secretary becomes aware of it. Common scenarios:
- A founder transfers shares to a relative on a Saturday and informs the CS the following Monday — the 30-day window started on Saturday
- A board passes a resolution at a meeting in Bangalore but the chairperson signs the minutes only after returning to Mumbai a week later — the resolution date for MGT-14 is the date of the board meeting, not the signing of the minutes
- An ESOP grant is approved at a board meeting but the FMV certificate is received only later — the 30-day window for SH-6 register update (and PAS-3 if shares allotted on exercise) runs from the resolution date
Build a habit of treating every board meeting and every corporate transaction as a potential filing trigger. A 5-minute compliance check at the end of each board meeting prevents downstream defaults.
The Damocles sword — strike-off under Section 248
The Registrar of Companies has the power under Section 248 to remove a company's name from the register on grounds including continuous failure to file AOC-4 and MGT-7 for two consecutive years. Once struck off, the company cannot operate, cannot sue or be sued (except for limited purposes), and its bank accounts are frozen.
Restoration is possible via an application to the National Company Law Tribunal (NCLT) within 20 years of strike-off, but the process typically takes 6–12 months and costs ₹50,000–₹2,00,000 in professional fees alone, plus all the back-filings and penalties. Best practice: never let two consecutive annual filings slip — even a token filing keeps the company alive while you sort out the underlying issues.