Form DPT-3 — Return of Deposits and Non-Deposits

How to file

Step-by-step process — from trigger event to ROC approval.

1. 01
   Identify reportable balances as on 31 March

   Review the balance sheet for: (a) deposits (Section 73 — public deposits, rare for private companies and small companies), (b) amounts not considered deposits under Rule 2(1)(c) — director loans, holding-company loans, share application money pending allotment, security deposits from employees, ECBs, advances from customers, convertible notes. Classify each balance.

2. 02
   Obtain director loan declarations

   For every director loan outstanding, obtain a written declaration that the loan is from the director's own funds and not borrowed. This declaration must be in place before 31 March to qualify the loan as 'not considered deposit'. Without the declaration, the loan is treated as a deposit and triggers heavier Section 73 obligations.

3. 03
   Check share application money age

   Any share application money received from a person and pending allotment for more than 60 days becomes a deposit (Rule 2(1)(c)(vii)). If allotment has not happened within 60 days, refund the money or treat it as a deposit. As on 31 March, calculate the age of every unallotted application.

4. 04
   Obtain auditor certificate (where applicable)

   If the company has accepted deposits within the meaning of Section 73, the statutory auditor must certify the deposit balance, the deposit insurance position, the deposit repayment reserve, and compliance with Rules 13 and 14. Most private companies don't have Section 73 deposits — they only have Rule 2(1)(c) balances.

5. 05
   Prepare the e-form

   Download DPT-3 from MCA21. Enter CIN, financial year (1 April to 31 March), opening and closing balances of deposits and non-deposits, party-wise breakdown. Choose the right purpose of filing — Annual Return (default), One-time Return (rarely used now), or Both.

6. 06
   Affix DSCs and submit by 30 June

   DSC of a director and the auditor (where deposits are accepted) or the certifying practising professional. Run pre-scrutiny. Upload, pay slab fee plus any delay additional fee. Save the SRN. Most companies file in May to leave a buffer for any data corrections.

Attachments required

Documents to prepare before opening the e-form.

• Auditor's certificate (only when the company has accepted deposits within the meaning of Section 73)
• List of depositors with name, PAN, amount, date of deposit, rate of interest, maturity date — for actual deposits
• Statement of amounts received but not considered deposits, with party-wise breakdown — the common case for startups
• Copy of the trust deed (where deposits are secured by a trust deed)
• Copy of the instrument creating charge (for secured deposits) — separate CHG-1 filing also applies
• Latest audited balance sheet excerpt showing the relevant balances

Common pitfalls

Where filings get rejected, delayed, or flagged in due diligence.

• Assuming DPT-3 is only for companies that accept public deposits — wrong. Every company (except Government companies) with any outstanding amount under Rule 2(1)(c) must file. Founder loans, share application money over 60 days old, and holding-company loans all trigger DPT-3.
• Missing the share-application-money trap — money received from investors before allotment becomes a deposit if not allotted within 60 days (Rule 2(1)(c)(vii)). At year-end, any unallotted share application money must be reported in DPT-3.
• Not reporting director loans — Rule 2(1)(c)(viii) excludes director loans from 'deposits' only if the director gives a written declaration that the loan is not from borrowed funds. The exclusion is conditional, and the loan is still reportable in DPT-3 as 'not considered deposit'.
• Forgetting convertible note balances — DPIIT-recognised startups have a carve-out for convertible notes issued under the startup framework, but the balance is still reportable in DPT-3 (under the 'not considered deposit' section).
• Treating a nil return as optional — even when there is nothing to report, a nil DPT-3 is required for companies that had outstanding amounts at any point during the year. When in doubt, file a nil return.
• Not reconciling DPT-3 to the balance sheet — the amounts disclosed in DPT-3 must reconcile to specific line items in the audited balance sheet. ROC scrutiny matches DPT-3 against the AOC-4 financials.

Frequently asked questions

Practical answers to the questions CS and CA teams hear most.

Related forms

Filings that commonly trigger together with Form DPT-3.