By CA Ashish, Ashish Jayalata & Associates, Chartered Accountants, Ghaziabad | Published: 24 October 2026
What MCA has announced
The Ministry of Corporate Affairs has allowed companies to file FY 2025-26 financial statements up to 31 December 2026 and annual returns up to 31 January 2027, without additional fees. The relaxation is granted by General Circular No. 05/2026 dated 24 October 2026 (File No. Policy-17/111/2022-CL-V-MCA), issued by the Policy division of MCA.
The circular records that MCA received representations from various stakeholders seeking more time for FY 2025-26 annual filings. These included ICSI's letter of 9 October 2026, which cited MCA21 V3 portal issues and the heavier data capture in the revised e-forms. The relief arrives six days before AOC-4 would have fallen due for companies that held their AGM on 30 September 2026.
The relief is narrower than it first looks. It waives additional fees for a window; it does not move the AGM deadline, and it does not cover every annual form.
Extended dates at a glance
| e-Form (FY 2025-26) | Statutory due date | No additional fee up to |
|---|---|---|
| AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | 30 days from AGM (Section 137) | 31 December 2026 |
| MGT-7, MGT-7A | 60 days from AGM (Section 92) | 31 January 2027 |
For a company that held its AGM on 30 September 2026, the statutory dates were 30 October 2026 for AOC-4 and 29 November 2026 for MGT-7/MGT-7A.
Conditions attached to the relaxation
The AGM timeline is not extended. Paragraph 3 of the circular states that it shall not be construed as extending the statutory time for holding AGMs. Companies that missed the timelines remain liable under the Act. A company that did not hold its AGM by 30 September 2026, and did not obtain an ROC extension under Section 96(1), stays in default under Section 99. Filing AOC-4 within the relaxed window does not cure that default.
Missing the window costs more than it appears. Paragraph 4 provides that filings made after the relaxation period attract all fees, including additional fees under the Companies (Registration Offices and Fees) Rules, 2014, counted "from the date when such filings were actually due under the Act". A company that files AOC-4 on 5 January 2027 therefore pays additional fees for the delay from 30 October 2026, not for five days.
First AGMs follow their own clock. A company whose first financial year ended on 31 March 2026 can hold its first AGM up to 31 December 2026 under Section 96(1). Its AOC-4 and MGT-7 statutory due dates may already fall after the relaxed dates, so the circular adds little for such companies.
Forms outside the relaxation
Paragraph 2 of the circular lists only the five AOC-4 variants and MGT-7/MGT-7A. ICSI had also sought relief for ADT-1 and DIR-12, but neither is named, so their normal timelines and fees apply.
- ADT-1 (Section 139): due within 15 days of the AGM, so mid-October for a 30 September AGM. Additional fees continue to run.
- DIR-12: due within 30 days of the change in directorship. No relaxation.
- MGT-14, CHG-1, PAS-3 and other event-based forms: normal timelines apply.
- LLP Form 8 (due 30 October) and Form 11: LLPs are outside this circular altogether.
What companies should do now
- File ADT-1 immediately if it is still pending. It is outside the relaxation and its additional fee is already accruing.
- Check the AGM position. If the AGM was not held by 30 September 2026 and no extension was granted, address the Section 96 default separately. The filing relaxation does not help here.
- Do not treat 31 December and 31 January as soft dates. Because late fees after the window count from the original due date, a few days' slippage past the window can cost several months of additional fees.
- Use the time on data quality. The revised V3 AOC-4 and MGT-7 capture far more data inside the form. Reconcile shareholding, director details, related party data and CSR figures with the signed financial statements before uploading.
- File well before the cut-off. Portal congestion in the last week of December and January has been routine. Plan AOC-4 by mid-December and MGT-7/7A by mid-January.
- Keep the circular on record. Retain a copy of General Circular 05/2026 with the filing papers in case of a fee dispute.
Frequently asked questions
Has the AGM due date for FY 2025-26 been extended? No. Paragraph 3 of the circular expressly says it does not extend the time for holding AGMs.
Does the relaxation cover OPCs? OPCs file AOC-4 within 180 days of the financial year end, which was 27 September 2026. The circular extends AOC-4 filing for FY 2025-26 for "companies" without excluding any class, so OPCs that missed 27 September appear to be covered up to 31 December 2026.
Is ADT-1 extended? No. Paragraph 2 covers only the AOC-4 variants and MGT-7/MGT-7A.
If AOC-4 is filed on 2 January 2027, how is the additional fee calculated? From the original statutory due date (30 days after the AGM), not from 31 December 2026.
Does this apply to LLPs? No. LLP Form 8 and Form 11 are governed by the LLP Act, 2008 and are not covered.
Closing note
General Circular 05/2026 gives companies roughly two more months for AOC-4 and MGT-7/7A, but only on the fee side. The AGM default, ADT-1 and other event-based forms stay on their statutory clocks.
Disclaimer: This article is for general information only and reflects the position as on 24 October 2026. It is not professional advice. Readers should verify the current position and take advice specific to their facts before acting.
