DPT-3

Form DPT-3 is the annual return of deposits filed by every company (other than a Government company) with the Registrar of Companies under Rule 16 of the Companies (Acceptance of Deposits) Rules 2014.

Due date: June 30 every year, covering the financial year ended March 31.

What is reported:

• Deposits outstanding as on March 31 (within the regulated definition under Section 73)
• Amounts received but not considered deposits under Rule 2(1)(c) — this is the catch for startups, because it covers:
• - Loans from directors (where the director has given a declaration that the funds are not borrowed)
• - Loans from a holding company
• - Money received as share application money pending allotment, if not allotted within 60 days
• - Money received from an employee up to their annual salary as a non-interest-bearing security deposit
• - External Commercial Borrowings (ECBs)
• - Convertible note proceeds issued to a person under the DPIIT-recognised startup framework (limited carve-out)

Why startups often miss this:

Most early-stage Indian companies take founder loans, working-capital advances from a holding company, or hold share application money at some point. These are 'not deposits' but must still be reported in DPT-3.

Penalty: Section 73 read with Rule 21 — fine of up to ₹5,000 plus ₹500 per day of continuing default for the company, with similar consequences for officers in default. The bigger risk is the MCA inquiry that follows non-filing — discoverability is automatic via balance sheet mismatch.

Attachments:

• Auditor's certificate (only when there are deposits — Section 73 deposits)
• List of depositors (Section 73 deposits)
• Statement of amounts not considered deposits (the common case for startups)

Pitfall: Many CFOs assume DPT-3 is only required if the company has accepted public deposits. Wrong. Even ₹1 of founder loan or ₹1 of share application money outstanding on March 31 triggers DPT-3. When in doubt, file a nil return.