AOC-4 and MGT-7 Due Date Extended: What the MCA Circular Changes

Yes, the Ministry of Corporate Affairs (MCA) has extended the ROC annual filing dates for FY 2025-26. Under General Circular No. 05/2026, dated 24 October 2026, companies can file Form AOC-4 (financial statements) till 31 December 2026 and Forms MGT-7 and MGT-7A (annual return) till 31 January 2027, without paying additional fees. The deadline for holding the Annual General Meeting (AGM) is not extended.

If you run a company in India, your phone is probably full of forwards saying "MCA has extended the date!" Some are right. Some are half right. A few could cost you money. So here is what actually happened, straight from the official circular.

The normal dates below assume your AGM was held on 30 September 2026. One Person Companies and first-year companies have different dates: see the next table.

Normally, AOC-4 is due within 30 days of your AGM and MGT-7 within 60 days. The new dates are fixed calendar dates, the same for every company that held its AGM on time, whatever the AGM date.

Not sure which form your company must file? Your AGM date is in your AGM minutes, and your incorporation date is on your Certificate of Incorporation. We are a Delhi NCR-based firm and we help businesses across India.
WhatsApp us on +91 70551 07773 and we will explain it in plain words. You are also welcome to visit our office.

Most forwards skip this part. Four things have not changed.

1. Your AGM date. Paragraph 3 of the circular clearly says it does not extend the time for holding the Annual General Meeting. For a company with a 31 March year-end, the AGM is normally due by 30 September. If you missed it, this circular does not fix that. Under Section 99 of the Companies Act, 2013, the company and each officer in default can be fined up to ₹1 lakh, plus up to ₹5,000 for every day the default continues.
2. ADT-1 and DIR-12. These forms, for auditor appointment and director changes, are not mentioned in the circular. ICSI asked MCA for relief on both in its 9 October 2026 letter, but the circular gives none, so their normal due dates stand.
3. Anything filed after the new dates. Paragraph 4 says a late filing pays all fees, including additional fees, counted from the original due date and not from 31 December. Take an example. AOC-4 was due on 30 October 2026 and you file on 15 January 2027. That is 77 days of delay, or ₹7,700 additional fee for that one form, on top of the normal filing fee. MGT-7 adds its own: due 29 November 2026 and filed on 15 February 2027, that is 78 days, or another ₹7,800.
4. LLP forms. The circular covers only company forms. LLP Form 8 for FY 2025-26 was due on 30 October 2026 and Form 11 on 30 May 2026, and neither date has moved.

The circular is also silent on refunds, so if you already paid an additional fee, do not count on getting it back.

The circular only says MCA received requests from stakeholders. The Institute of Company Secretaries of India (ICSI) had listed the problems in its 9 October letter: MCA21 V3 portal downtime, logouts in the middle of a filing, and DSC and payment errors.

This has happened before. For FY 2024-25, MCA first allowed filing till 31 December 2025 and later stretched it to 31 January 2026. Will there be another extension now? Honestly, we do not know, and nobody outside MCA does. Waiting for one is a gamble.

Our view: file AOC-4 in November, while the portal is quieter. The last two weeks of December are when everyone else will be trying.

1. Close your books first. Finish the audit and get board approval for the financial statements.
2. Check your digital signatures. Directors and the auditor need a valid DSC. If one has expired, see our Digital Signature Certificate guide.
3. Pick the right form. AOC-4, XBRL or CFS version? MGT-7 or MGT-7A? A wrong choice means a rejected form and lost days.
4. Match your numbers and records. Financials, shareholding and director details should agree with your books and past MCA filings.
5. File early and keep proof. Do not wait for the last week. Save the SRN and screenshots of every payment and submission, in case the portal acts up.

Quick Tip: 31 December 2026 is also the due date for GSTR-9, the GST annual return, if it applies to you. Book your accountant's time for both early, or finish AOC-4 first.

Stuck on any step? Tell us what is pending and we will tell you what to do first.

If your audit is done, file AOC-4 now and MGT-7 straight after. If it isn't, book it this week, because the new dates only help if your books are ready. Here is what we can't control.We cannot make the MCA portal faster, and we cannot predict another extension. What we can do is get your side ready well before the date.

At one-startup, we help companies check their financial statements and company details, choose the correct AOC-4 and MGT-7 forms, prepare the filing, submit it on the MCA portal and share the receipts as proof. If something falls outside the circular, like a missed AGM or a pending ADT-1, we will tell you plainly.

We are a private professional firm, not a government body, and you can always file on the official MCA website yourself. If you would rather hand it to someone who does this every day, we are here. Our team is based in Delhi NCR and supports businesses in every state through virtual meetings, phone and WhatsApp.

If you prefer a face-to-face chat, walk into our office at A-1217, 12th Floor, Tower 3, NX One Byte, Techzone IV, Greater Noida West. Write to us at contact@one-startup.in or WhatsApp +91 70551 07773. Think of us as the friend who has already read the circular, so you do not have to.

What happens when you reach out: we check what you actually need, then confirm our fee (+ GST) and the government charges in writing before you pay.

This blog is general information based on MCA General Circular No. 05/2026. Please confirm the latest position on mca.gov.in before filing.

Published: 27 October 2026