ROC annual filing: AOC-4, MGT-7 & due dates.

What is ROC annual filing?

"ROC annual filing" refers to the set of forms every company registered under the Companies Act, 2013 must file with the Registrar of Companies each financial year, regardless of turnover, profitability, or whether the company actually traded. It is separate from — and comes after — statutory audit and the Annual General Meeting (AGM). The two forms every practitioner deals with on almost every file are AOC-4 (financial statements) and MGT-7 / MGT-7A (annual return).

Missing this is not a paperwork inconvenience: it triggers escalating additional fees, and repeated defaults over consecutive years expose the company to being struck off the register and its directors to disqualification. For a CA, ROC filing is one of the most schedule-driven parts of practice — the due dates are fixed by statute, not negotiable with the client.

The annual filing framework, form by form

The filing sequence follows the AGM. Board approves financials → AGM adopts them → forms go to the ROC within the statutory window measured from the AGM date, not the financial year-end. The four forms that recur every year for a typical private or public company:

AOC-4 carries the Balance Sheet, Statement of Profit & Loss, cash flow statement (where applicable), the Board's Report, and the auditor's report as attachments. MGT-7/7A is the return of the company's structure as of the financial year-end — shareholding pattern, directors and KMP, registered office, and other statutory particulars — filed after AOC-4 in the same season since it references the same AGM date.

Verify the exact due-date windows, form versions and applicability on the MCA portal before finalising a filing calendar — the number of days from the AGM, XBRL applicability thresholds, and the small-company / OPC definitions used for MGT-7A are all periodically revised.

Worked example — mapping the filing calendar

Take a private limited company whose financial year ends 31 March, and whose AGM is held on 30 September of the same calendar year (the outer limit for an AGM under the Act, absent an extension). Working from that AGM date with the "within" periods above:

• ADT-1 (auditor appointment) — due within 15 days of the AGM, i.e. by 15 October.
• AOC-4 (financials) — due within 30 days of the AGM, i.e. by 30 October.
• MGT-7 / MGT-7A (annual return) — due within 60 days of the AGM, i.e. by 29 November.

If the same company's AGM slips to 15 October instead, every downstream due date shifts with it — AOC-4 moves to roughly 14 November and MGT-7 to roughly 14 December. This is the single most common scheduling mistake: teams anchor the filing calendar to the financial year-end (31 March) instead of the actual AGM date, and miss the shifted deadline when the AGM itself runs late.

(Illustrative only — always confirm the current "within X days" windows and any COVID-era or notification-based relaxations on the MCA portal for the year in question.)

Late fees — the structure, not the numbers

ROC forms filed after the due date attract an additional fee calculated per day of delay, layered on top of the normal filing fee — there is no grace period once the window closes, and the additional fee typically accrues from day one of the delay rather than after a threshold. Because it compounds daily, a filing that is a few months late can cost a multiple of the original fee.

Beyond the fee, sustained non-filing carries structural consequences: the ROC can treat continuous default as grounds to strike the company off the register under its powers for companies not carrying on business, and directors of a defaulting company can be disqualified from being reappointed or appointed to other companies for defaults spanning multiple consecutive financial years.

Do not quote an exact late fee slab or disqualification threshold to a client from memory — verify the current fee table and thresholds on the MCA portal each filing season, since these have been revised more than once.

Practical filing checklist for a CA

• Confirm the AGM date first. Every downstream due date is computed from it, not the year-end — get this locked before building the calendar.
• Check XBRL applicability separately for each company — the AOC-4 XBRL requirement applies to specific classes of companies (typically listed companies and certain thresholds by paid-up capital or turnover) and is revised periodically; don't assume last year's classification still holds.
• Re-test small-company / OPC status every year before defaulting to MGT-7A — paid-up capital or turnover growth can move a company out of that bracket.
• Sequence DIN KYC (DIR-3 KYC) and ADT-1 ahead of AOC-4 — a lapsed DIN or an unfiled auditor appointment can block later forms on the MCA portal.
• Reconcile the financials being filed against the audited set signed by the auditor — AOC-4 attachments must match what the AGM actually adopted, not a subsequently revised draft.
• Track DPT-3 separately — it isn't AGM-linked like the other three, so it's easy to lose inside an AGM-driven filing calendar.
• Build a standing filing calendar per client, not per season — the biggest source of late fees in practice is a client roster large enough that AGM dates drift out of memory.

If your practice is tracking these deadlines across a client roster in spreadsheets, that's exactly where dates get missed as the roster grows. TatvaBooks' Practice plan includes a compliance-calendar view across all your clients' entities — GST, TDS and ROC-linked dates in one place — so nothing depends on someone remembering an AGM date from six months ago. See what's on the Practice plan, or book a walkthrough.

Frequently asked questions