India MCA Extends Annual Filing Deadlines to 31 December 2025

The Ministry of Corporate Affairs extends annual filing deadlines to 31 December 2025, providing significant relief for companies adapting to India’s new e-filing framework. For compliance professionals managing FY 2024-25 annual returns and financial statements, this extension offers essential additional time without the burden of late filing penalties.

The timing couldn’t be more relevant. As organisations navigate the transition to revised e-forms on the MCA-21 Version 3 portal, this deadline extension acknowledges the practical challenges of system adaptation while maintaining regulatory standards.

Context behind the extension

The MCA recently deployed MCA-21 Version 3, introducing substantially revised e-forms for annual corporate filings. These updates affect core compliance documents including MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), and AOC-4 (XBRL).

The changes go beyond cosmetic interface updates. The revised forms incorporate enhanced data fields, updated validation requirements, and restructured formats designed to improve transparency and align with contemporary corporate governance standards.

Following representations from stakeholders across the corporate ecosystem—including company secretaries, chartered accountants, and finance professionals—the MCA recognised that organisations needed additional time to familiarise themselves with the new filing processes and requirements.

What the circular provides

Through General Circular No. 06/2025 dated 17 October 2025, the Ministry extended the filing deadline for financial statements and annual returns pertaining to FY 2024-25 to 31 December 2025, without any additional fees.

The original statutory deadlines were:

• Financial statements (Form AOC-4 series): 30 October 2025 (within 30 days of AGM)
• Annual returns (Forms MGT-7/MGT-7A): 29 November 2025 (within 60 days of AGM)

Under this circular, companies can now complete these filings by 31 December 2025 without incurring additional fees under the Companies (Registration Offices and Fees) Rules, 2014.

This represents substantial relief for companies whose original deadlines have passed. Rather than accumulating late fees from the original due dates, organisations filing before year-end will only pay the standard filing fees.

Scope of the extension

The fee waiver applies to all annual filing forms for FY 2024-25 on the MCA V3 portal:

Financial Statement Forms:

• AOC-4 – Standalone financial statements
• AOC-4 CFS – Consolidated financial statements
• AOC-4 NBFC (Ind AS) – For non-banking financial companies using Indian Accounting Standards
• AOC-4 CFS NBFC (Ind AS) – Consolidated statements for NBFCs
• AOC-4 (XBRL) – For companies with XBRL filing requirements

Annual Return Forms:

• MGT-7 – For companies other than OPCs and small companies
• MGT-7A – For one-person companies and small companies

All companies required to file these forms for the financial year ended 31 March 2025 can take advantage of this extension.

Critical distinction: AGM deadlines remain unchanged

It’s essential to understand what this circular does not extend. The MCA has explicitly clarified that this relaxation does not extend the statutory deadline for holding Annual General Meetings.

Under Section 96 of the Companies Act, 2013, companies must hold their AGM within six months from the end of the financial year. For FY 2024-25 (ending 31 March 2025), this means AGMs should have been completed by 30 September 2025 for most companies.

The filing extension is independent of AGM obligations. Companies that failed to hold their AGM within the statutory timeline remain subject to penalties under Section 99 of the Companies Act, regardless of when they file the related forms.

This separation is logical: the AGM is where shareholders approve financial statements and discharge directors’ duties. The MCA filing is the formal submission of those approved documents to the Registrar of Companies. The approval process has its own timeline, separate from the filing process.

Recommended compliance approach

For organisations yet to complete their FY 2024-25 filings, consider this structured approach:

1. Verify AGM compliance status: Confirm that your AGM was held within the statutory period. If not, address this compliance gap separately, as AGM-related penalties are not covered by this circular.
2. Prepare documentation systematically: Ensure all supporting documents are ready: approved financial statements, board and shareholder resolutions, audit reports, declarations, and certifications. While the forms are new, the underlying documentation requirements remain consistent.
3. Allocate time for form familiarisation: The MCA V3 portal interface and form structures differ from previous versions. Review the updated forms well in advance to identify any data requirements or validation rules that may affect your filing process.
4. Coordinate with professional advisors: If you engage external professionals for statutory filings, confirm their availability and familiarity with the new forms. Many practices are managing high volumes of filings during this transition period.
5. Plan for early completion: Although the extension runs to 31 December 2025, avoid last-minute filings. Portal traffic increases near deadlines, and technical issues can arise. Targeting completion by mid-December provides a reasonable buffer.

Understanding post-deadline implications

After 31 December 2025, any delayed filings will attract normal and additional fees as per the Companies (Registration Offices and Fees) Rules, 2014, calculated from the original due date.

This means filings submitted after the circular’s expiry date will incur additional fees calculated from the original statutory deadline (30 October or 29 November 2025), not from 1 January 2026. The extension pauses the additional fee clock; it doesn’t reset it.

This is a one-time measure tied specifically to the MCA V3 portal transition, not a permanent change to filing timelines.

Who benefits from this extension

The practical impact spans multiple stakeholder groups:

• Small and medium enterprises with limited compliance resources gain additional time to navigate the new system without immediate penalty exposure.
• Companies with complex reporting structures—particularly those filing consolidated financials or managing NBFC-specific requirements—benefit from extra time to understand new XBRL formats and Ind AS specifications.
• Newly incorporated companies approaching their first annual filing cycle can complete their obligations without the pressure of accumulated penalties while learning the process.
• Compliance professionals managing multiple entities avoid the October-November compliance bottleneck that typically concentrates workloads during India’s peak filing season.

Broader regulatory perspective

This extension reflects the MCA’s continued responsiveness to stakeholder feedback during system transitions. Similar relief measures have been provided during previous portal upgrades and regulatory changes, recognising that effective compliance requires adequate adaptation time.

The MCA-21 Version 3 platform represents a significant modernisation of India’s corporate registry infrastructure. The enhanced forms capture more detailed information, improve data quality, and support more effective regulatory oversight. While the transition requires adjustment, the long-term benefits include improved compliance processes and better data management.

For multinational corporations with Indian subsidiaries, this extension provides valuable time to coordinate statutory compliance with global reporting cycles and ensure alignment between parent company requirements and local regulatory obligations.

What’s next?

Managing an annual filing process requires detailed planning and full legal awareness. For more insights into processes in other jurisdictions, explore our article Understanding NACE Codes in Germany.

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