AOC-4 and MGT-7 Due Date Extended for FY 2025-26: New Dates and What Still Applies

Quick answer: Yes. Through General Circular No. 05/2026 dated 24 October 2026, the Ministry of Corporate Affairs (MCA) has allowed companies to file financial statements in Form AOC-4 for FY 2025-26 up to 31 December 2026, and annual returns in Form MGT-7 or MGT-7A up to 31 January 2027, without paying additional fees. The circular does not extend the time for holding the AGM, and it does not cover other forms such as ADT-1.

What the MCA circular says

Every company has to file its audited financial statements with the Registrar of Companies under Section 137 of the Companies Act, 2013, and its annual return under Section 92. Late filing normally attracts an additional fee of ₹100 per day for each form.

After receiving representations from stakeholders asking for more time, the MCA issued General Circular No. 05/2026 on 24 October 2026. It relaxes the additional fee for FY 2025-26 filings made within the following windows:

• Financial statements: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) can be filed up to 31 December 2026.
• Annual returns: MGT-7 and MGT-7A can be filed up to 31 January 2027.

Filings made within these dates will not attract additional fees. Only the normal filing fee applies.

Original due dates versus the extended dates

Under the Act, AOC-4 is due within 30 days of the annual general meeting (AGM) and MGT-7 is due within 60 days of the AGM. For a company with a 31 March year end that held its AGM on the last permitted day, 30 September 2026, the position is:

• AOC-4: normal due date 30 October 2026; can now be filed without additional fees up to 31 December 2026.
• MGT-7 / MGT-7A: normal due date 29 November 2026; can now be filed without additional fees up to 31 January 2027.

If your AGM was held earlier, your normal due dates were also earlier. The relaxation still applies as long as the form is filed within the extended window.

What the extension does not cover

The AGM deadline

The circular states clearly that it does not extend the statutory time for holding AGMs. A company that has not held its AGM within the time allowed under Section 96 (or within any extension granted by the Registrar) remains in default, and the consequences under the Act continue to apply. The fee relaxation only helps with filing the forms after the AGM.

Other e-forms

The relaxation names only the AOC-4 group of forms and MGT-7/MGT-7A. Forms such as ADT-1 (auditor appointment, due within 15 days of the meeting) and event-based forms are not mentioned, so their normal due dates and fees continue. LLP annual filings in Form 8 and Form 11 are also outside this circular.

Filings after the extended dates

Paragraph 4 of the circular is important. If a company files after 31 December 2026 (AOC-4) or 31 January 2027 (MGT-7), additional fees will be charged from the original due date under the Act, not from the extended date. For example, an AOC-4 originally due on 30 October 2026 and filed on 10 January 2027 would attract additional fees for the full period of delay counted from 30 October.

Does it apply to OPCs and small companies?

The circular does not exclude any class of company. MGT-7A, which is the simplified annual return used by One Person Companies and small companies, is expressly included. An OPC does not hold an AGM and must file AOC-4 within 180 days of the end of the financial year, which for FY 2025-26 was 27 September 2026. Since the circular covers AOC-4 filings for FY 2025-26 generally, an OPC that has not yet filed can use the window up to 31 December 2026. It is still sensible to check your company's specific due dates before relying on the relaxation.

What companies should do now

The extra time is useful, but it is better to treat it as a buffer rather than a new target. Annual filings depend on several pieces coming together, and portal traffic usually rises close to any deadline.

• Confirm the AGM date and keep the signed minutes, notice and attendance records ready, since both forms refer to the AGM.
• Make sure the audited financial statements, board's report and auditor's report are final and signed, and that DSCs of the signing director and professional are valid.
• Check that ADT-1 has been filed for the auditor appointed or ratified at the AGM, since it is not covered by the relaxation.
• Prepare the shareholding, director and meeting details needed for MGT-7 or MGT-7A, and reconcile them with the company's registers.
• Plan to file AOC-4 well before 31 December 2026, and MGT-7 after that, so that any portal or validation errors can be fixed within the window.

You can track these and other monthly dates on our compliance calendar.

Key points

• MCA General Circular No. 05/2026 is dated 24 October 2026.
• AOC-4 and its variants for FY 2025-26 can be filed up to 31 December 2026 without additional fees.
• MGT-7 and MGT-7A for FY 2025-26 can be filed up to 31 January 2027 without additional fees.
• The AGM deadline is not extended, and ADT-1 and LLP forms are not covered.
• Filings after the extended dates attract additional fees counted from the original due date.

Frequently asked questions

Is the AGM due date for FY 2025-26 also extended?

No. The circular specifically says it should not be read as extending the time for holding AGMs. Only the filing of AOC-4 and MGT-7/MGT-7A gets the fee relaxation.

Will I get a refund if I already paid additional fees on AOC-4?

The circular does not provide for refunds of additional fees already paid. It only relaxes fees for filings made within the extended window.

What happens if I file AOC-4 on 5 January 2027?

The relaxation ends on 31 December 2026 for AOC-4. A filing on 5 January 2027 would attract additional fees of ₹100 per day calculated from the original due date, and the company and its officers may also face penalty proceedings for late filing.

Is LLP Form 8 or Form 11 covered by this extension?

No. The circular deals only with company filings in AOC-4 and MGT-7/MGT-7A. LLP filings follow their own due dates under the LLP Act and rules.

Get your annual filing done on time

Finaccle's CA-led team in Surat, Mumbai and Delhi prepares and files AOC-4, MGT-7 and related forms for private limited companies and OPCs, and coordinates with your auditor so the forms match the signed accounts. See our private limited company annual return filing service, our OPC annual filing service, or contact us to have your FY 2025-26 filings reviewed before the extended dates.