Annual compliance calendar for a private limited company

A private limited company's year holds two kinds of deadline, and mixing them up is what makes calendars wrong. Three dates are fixed to the calendar and do not move for anybody: DPT-3 by 30 June, DIR-3 KYC by 30 September, and MSME Form I by 31 October and 30 April. Three more are counted in days from the annual general meeting: ADT-1 at 15 days, AOC-4 at 30, and MGT-7 or MGT-7A at 60. Board meetings belong to neither group — section 173 sets a maximum gap between meetings rather than a date. (Checked against MCA, 7 September 2026.)

The consequence most calendars miss: moving the AGM moves three deadlines and none of the others, and moving it late moves nothing at all.

The three dates that never move

These are set by rule or by order, not by anything the company does, and they fall on the same day every year whether or not the accounts are ready.

DPT-3 is not only about deposits, and that is where private companies get caught. MCA's DPT-3 instruction kit (PDF) states that a company other than a Government company files the return "on or before 30th day of June every year, furnishing all information therein as on the 31st day of March of that year duly audited by the auditor of the company". The Explanation inserted into rule 16 by the Companies (Acceptance of Deposits) Amendment Rules, 2019, G.S.R. 42(E) (PDF) puts it beyond argument:

It is hereby clarified that Form DPT-3 shall be used for filing return of deposit or particulars of transaction not considered as deposit or both by every company other than Government company.

A company that has never accepted a deposit in its life may still owe the return, because a director's loan or unsecured borrowing sits in the second category. What counts as a transaction not considered a deposit is on the DPT-3 hub.

DIR-3 KYC binds the director, not the company. The DIR-3 KYC (Web) instruction kit (PDF) says every individual holding a DIN as on 31 March of a financial year files for that year "on or before 30th September of the immediate next financial year", and prices the miss separately from any filing fee: INR 5000 where the DIN has been deactivated for non-filing of KYC. The company is not the defaulter, but a deactivated DIN stops it signing anything. The procedure is on the director KYC guide.

MSME Form I is half-yearly, and its trigger is a payment delay rather than a turnover. The order at S.O. 368(E) of 22 January 2019 (PDF) applies to companies whose payments to micro and small enterprise suppliers "exceed forty five days from the date of acceptance or the date of deemed acceptance of the goods or services", and order 3 reads:

Every specified company shall file a return as per MSME Form I annexed to this Order, by 31st October for the period from April to September and by 30th April for the period from October to March.

(Checked 7 September 2026.) MCA's MSME half-yearly return page carries the current form.

The three that move with the AGM

Everything downstream hangs off the meeting. The first proviso to section 96(1) of the Companies Act, 2013 gives a company other than a new one "a period of six months, from the date of closing of the financial year" to hold it — so for FY 2025-26, which closed on 31 March 2026, the AGM was due by 30 September 2026. Three filings are then counted in days from the date it is actually held:

• ADT-1, the notice of the auditor's appointment, within 15 days of the meeting. Section 139(1) requires the company to "file a notice of such appointment with the Registrar within fifteen days of the meeting in which the auditor is appointed".
• AOC-4, the financial statements, "within thirty days of the date of annual general meeting" under section 137(1).
• MGT-7 or MGT-7A, the annual return, "within sixty days from the date on which the annual general meeting is held" under section 92(4).

All three quotations are from the Companies Act 2013 as published by MCA (PDF). (Sections 96, 139, 137 and 92, checked 7 September 2026.) Which of the two annual return forms applies is a separate test — MGT-7 or MGT-7A works it through. The fee, the additional fee and the due date for the year being filed are on the AOC-4 hub and the MGT-7 hub, and the due date calculator runs the three clocks off an AGM date.

An AGM held early therefore pulls three deadlines forward with it. A company that meets on 5 August has an AOC-4 due in early September, not in late October.

Holding the AGM late does not buy time

Both annual filing clocks have a second limb that runs from the date the meeting should have been held, not the date it was. Section 92(4) requires the annual return within sixty days of the AGM,

or where no annual general meeting is held in any year within sixty days from the date on which the annual general meeting should have been held together with the statement specifying the reasons for not holding the annual general meeting

Section 137(2) does the same for the financial statements, requiring them within "thirty days of the last date before which the annual general meeting should have been held". (Checked 7 September 2026.)

So a company that lets 30 September pass without meeting does not get sixty days from whenever it eventually meets. Its MGT-7 clock started on 30 September anyway. What that costs, in the order the consequences arrive, is in what happens if you miss the ROC annual filing deadline.

Board meetings are a gap rule, not a date

Nothing in section 173 names a day. It sets a count and a maximum interval, and small companies get a lighter version:

(1) Every company shall … hold a minimum number of four meetings of its Board of Directors every year in such a manner that not more than one hundred and twenty days shall intervene between two consecutive meetings of the Board

(5) A One Person Company, small company and dormant company shall be deemed to have complied with the provisions of this section if at least one meeting of the Board of Directors has been conducted in each half of a calendar year and the gap between the two meetings is not less than ninety days

Two details are easy to lose. Sub-section (5) counts in halves of a calendar year, while every other deadline on this page runs on the financial year. And the 90-day gap is a minimum, not a ceiling, so two meetings held a fortnight apart do not qualify.

One item attaches to a meeting rather than a date: section 184(1) requires every director to disclose his concern or interest "at the first meeting of the Board in every financial year" — the disclosure practitioners file as MBP-1. (Sections 173 and 184, checked 7 September 2026.)

What to do next

1. Diary the fixed dates first — 30 June, 30 September, 31 October and 30 April. They do not wait for the accounts.
2. Check whether the books carry money that is neither a deposit nor share capital. If they do, DPT-3 is due whether or not the company has ever taken a deposit.
3. Fix the AGM date, then count 15, 30 and 60 days forward from it. That is the whole AGM-linked half of the calendar.
4. Confirm every director's DIN is in approved status well before 30 September; reactivation carries its own fee and blocks signing in the meantime.
5. Count the gap since the last Board meeting before booking the next one, rather than counting meetings at the year end.

What this does not cover

This is the shape of the year, not the arithmetic of any one form. Fees, additional fees and the current year's exact due dates live on the form hubs and move with the rules.

It leaves out filings that switch on at a threshold or an event rather than annually — AOC-4 CFS and AOC-4 XBRL, CSR-2 under section 135, cost audit under section 148, secretarial audit under section 204, BEN-2 and the MGT-8 certification — and returns that are not MCA's, such as the FLA return to the Reserve Bank of India.

Two things we could not resolve. First, the Gazette copy of S.O. 368(E) does not agree with itself: the English text of order 3 reads "by 30th April for the period from October to March", while the Hindi text of the same order reads 30 March. We found no MCA corrigendum reconciling the two, and the English text is the one the form is built on.

Second, the third proviso to section 96 lets the Registrar extend the time for an AGM other than the first, by up to three months for special reason. Whether an extension shifts the "should have been held" dates in sections 92(4) and 137(2) is not something we found MCA stating either way, and it is not a question to guess at with a daily fee attached.