CAtrak
ROC / MCA9 min read1 April 2026

ROC Compliance Checklist for Private Limited Companies

Private limited companies in India must file multiple forms with the Registrar of Companies (ROC) every year. Missing these filings leads to penalties, additional fees, and in extreme cases, striking off of the company. This checklist covers every annual ROC obligation for a private limited company in FY 2026-27.

AGM — Annual General Meeting (by 30th September)

Every private limited company must hold its AGM within 6 months from the end of the financial year (31st March), making the deadline 30th September. The AGM agenda typically includes adoption of financial statements, appointment/reappointment of auditors, declaration of dividends, and other ordinary business. The gap between two AGMs must not exceed 15 months. First AGM of a newly incorporated company must be held within 9 months from the FY end.

AOC-4 — Financial statements (by 29th October)

AOC-4 is the filing of annual financial statements (balance sheet, profit & loss, cash flow statement) with the ROC. It must be filed within 30 days of the AGM. If AGM is on 30th September, AOC-4 is due by 29th October. Companies with subsidiaries must file AOC-4 CFS (consolidated financial statements) with the same deadline. The filing requires the board's approval and adoption at the AGM.

MGT-7/MGT-7A — Annual return (by 28th November)

MGT-7 (or MGT-7A for OPC and small companies) is the annual return filed within 60 days of the AGM. It contains details of the company's shareholders, directors, and changes during the year. If AGM is on 30th September, MGT-7 is due by 28th November. This filing requires a practicing CA/CS certification for companies with paid-up capital above ₹10 crore or turnover above ₹50 crore.

DIR-3 KYC — Director KYC (by 30th September)

Every director holding a DIN must complete DIR-3 KYC annually by 30th September. If the KYC was done with Aadhaar in the previous year, DIR-3 KYC-Web (online verification) is sufficient. New directors or those updating details must file the full DIR-3 KYC form. Failure to complete KYC results in DIN deactivation — the director cannot sign any MCA filing until the DIN is reactivated.

ADT-1 — Auditor appointment (within 15 days of AGM)

ADT-1 must be filed within 15 days of the AGM to intimate the ROC about the appointment or reappointment of the statutory auditor. If the AGM is on 30th September, ADT-1 is due by 14th October. This is a frequently missed filing because the deadline is tight. Set a reminder immediately after the AGM.

Other annual filings

DPT-3 (return of deposits) is due by 30th June for companies that accept deposits or have outstanding loans from members/directors. MSME-1 (outstanding payments to MSME suppliers) is due half-yearly — 30th April and 30th October. DIR-12 (appointment/cessation of directors) is event-based but should be reviewed annually. MGT-14 (filing of board resolutions) is due within 30 days of passing special resolutions. INC-20A (declaration of commencement of business) is a one-time filing within 180 days of incorporation.

Penalties for non-compliance

Late filing of ROC forms attracts additional fees that increase progressively: ₹200/day for delays up to 30 days, ₹400/day for 30-60 days, ₹600/day for 60-90 days, and so on up to ₹1,200/day for delays beyond 270 days. For a company that misses AOC-4 by 6 months, the additional fees alone can exceed ₹50,000. Persistent default can lead to the company being marked for striking off under Section 248.

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