Companies across India got some breathing room on 24 October 2026. The Ministry of Corporate Affairs (MCA) issued General Circular No. 05/2026, which lets companies file their FY 2025-26 financial statements and annual returns without paying additional fees for a few more weeks than the normal timeline allows.
In short, AOC-4 can now be filed without additional fees up to 31 December 2026, and MGT-7 and MGT-7A up to 31 January 2027. That sounds like a comfortable cushion, but there are a couple of conditions inside the circular that catch people out every year. Let us go through what the circular says, what it quietly leaves untouched, and how to plan your filings sensibly.
Quick Summary
The MCA’s General Circular No. 05/2026, as described in the update, provides additional time for companies to complete their FY 2025–26 annual statutory filings without additional filing fees. Eligible AOC-4 forms can be filed by 31 December 2026, while MGT-7 and MGT-7A can be filed by 31 January 2027, subject to the circular’s applicable conditions. Companies should use this relaxation to organise their documents and complete filings promptly.
- File AOC-4 on time: Prepare and submit the applicable financial statement form, including relevant CFS, XBRL or NBFC variants, by 31 December 2026.
- Complete annual return filing: File MGT-7 or the applicable MGT-7A by 31 January 2027, based on your company’s eligibility.
- Prepare financial documents: Keep approved financial statements, board reports, AGM details and supporting records ready for filing.
- Verify company information: Check the company’s master data, financial figures, director details and shareholding information before submitting forms to the MCA.
- Review the circular’s conditions: Confirm the scope of the fee relaxation and remember that it does not automatically waive other statutory obligations or penalties unrelated to the extension.
- Keep filing acknowledgements: Save the submitted forms, payment receipts and MCA acknowledgements for your company’s compliance records.
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MCA General Circular 05/2026: AOC-4 and MGT-7 Extension for FY 2025-26
The circular is titled “Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013”. The Ministry says it received representations from several stakeholders asking for more time to complete annual statutory filings for the financial year ended 31 March 2026, and it has agreed to give a one-time relaxation on the additional fee.
Two things are being relaxed:
- Financial statements: e-Forms 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 without additional fees.
- Annual returns: e-Forms MGT-7 and MGT-7A can be filed up to 31 January 2027 without additional fees.
New AOC-4 and MGT-7 Due Dates for FY 2025-26
| Form | What it is used for | Normal due date | Fee-free date now |
| AOC-4 and its variants | Filing financial statements with the ROC | Within 30 days of the AGM | 31 December 2026 |
| MGT-7 | Annual return of a company | Within 60 days of the AGM | 31 January 2027 |
| MGT-7A | Annual return for OPCs and small companies | Within 60 days of the AGM | 31 January 2027 |
If you are still sorting out which form does what, our explainer on the difference between AOC-4 and MGT-7 covers it in plain language.
AOC-4 and MGT-7 Last Date Without Additional Fees: Worked Example
Take a private limited company that held its AGM on 30 September 2026, the last permitted day for a company with a March year-end. Without the circular, its AOC-4 filing would have been due by 30 October 2026 and its MGT-7 filing by 29 November 2026. Under the circular, the same company can file AOC-4 by 31 December 2026 and MGT-7 by 31 January 2027 without additional fees.
| Particulars | Before the circular | After the circular |
| AGM held on | 30 September 2026 | 30 September 2026 |
| AOC-4 (without additional fees) | Up to 30 October 2026 | Up to 31 December 2026 |
| MGT-7 / MGT-7A (without additional fees) | Up to 29 November 2026 | Up to 31 January 2027 |
What MCA Circular 05/2026 Does Not Change?
This is the part worth reading twice. The relief is narrower than a headline suggests.
AGM Due Date Is Not Extended Under the Circular
The MCA has clarified that the circular does not extend the time for holding Annual General Meetings. A company that missed its AGM window is still answerable under the Companies Act, 2013 for that default. If your AGM is pending or has slipped past the due date, read our guide on extension of AGM, its procedure and consequences, and refresh your understanding of the rules around an Annual General Meeting.
Additional Fees Waived, but Normal ROC Filing Fees Still Apply
The relief is about the additional (late) fee. The prescribed ROC filing fee, which depends on the authorised capital of the company, still has to be paid as usual.
Late Filing After the Extended Date: Additional Fees From the Original Due Date
The circular is clear that filings made after it ceases to apply will attract all applicable fees, including additional fees, as provided under the Companies (Registration Offices and Fees) Rules, 2014, and these are counted from the date the filing was actually due under the Act. In other words, if you file on 5 January 2027 instead of 31 December 2026, you do not pay a few days of extra fee. You pay from the original due date, which could be as far back as October.
The standard additional fee is ₹100 per day, per form, and there is no upper cap. Two delayed forms, two meters running.
Should You File AOC-4 and MGT-7 Early or Wait Until the Extended Date?
Technically, you can wait. Practically, most finance teams and company secretaries would advise against it. Here is why:
- Year-end rush: December tends to be crowded with audits, tax work and portal traffic. Filing earlier lowers the risk of last-minute technical hiccups.
- Fewer surprises: Early filing leaves time to fix data mismatches between AOC-4, MGT-7 and other forms before the clock becomes tight.
- Business needs: Banks, investors and prospective partners often ask for the latest filed financials. A pending AOC-4 can slow down a loan, a funding round or a tender.
- No guarantee of another extension: Relief has come in stages in earlier years, but nothing in this circular promises a further window. Planning around a second extension is a gamble.
If your books are already audited and approved at the AGM, there is little reason to hold the filing back.
Penalty and Late Fee for AOC-4 and MGT-7 After the Extension
Beyond the daily additional fee, continued non-filing can lead to heavier trouble: penalties on the company and its officers in default, disqualification of directors under Section 164(2) of the Companies Act, and, over time, the Registrar initiating strike-off action under Section 248. We have broken down the numbers and consequences in our guide to the penalty for late ROC filing.
FY 2025-26 ROC Annual Filing Checklist for Companies
- Confirm the date your AGM was (or will be) held and make sure it falls within the statutory deadline.
- Get the audited financial statements, Board’s report and auditor’s report finalised and signed.
- Check which AOC-4 variant applies to you: standard, CFS, XBRL, or the NBFC (Ind AS) versions.
- Prepare the annual return details (shareholding, directors, meetings, charges) for MGT-7 or MGT-7A.
- Cross-check figures and director details across all forms to avoid resubmissions.
- Set an internal deadline well before 31 December 2026 for AOC-4 and 31 January 2027 for MGT-7/7A.
- Keep SRN receipts and filed copies safely for audit and due diligence needs.
AOC-4 and MGT-7 Filing Services by Kanakkupillai
Annual filings look simple on paper, but one wrong figure or an unattached document can send a form back for resubmission. Our team handles the full annual compliance for private limited companies, from reviewing financial statements to filing AOC-4 and MGT-7 and sharing the final receipts. If your business is based in the city, you can also look at our annual compliance filing support for companies in Chennai. Send us your documents early, and we will tell you exactly what is pending.
Need Help with AOC-4 and MGT-7 Annual Filings?
Get professional assistance with financial statement preparation, AOC-4 filing, MGT-7/MGT-7A annual returns and ROC compliance to help your company complete its MCA filings within the applicable deadlines.
FAQs on the MCA AOC-4 and MGT-7 Extension 2026
What is the new last date for AOC-4 for FY 2025-26?
Under MCA General Circular No. 05/2026, AOC-4 and its variants for FY 2025-26 can be filed without additional fees up to 31 December 2026.
What is the new last date for MGT-7 and MGT-7A for FY 2025-26?
MGT-7 and MGT-7A can be filed without additional fees up to 31 January 2027.
Does the circular extend the date for holding the AGM?
No. The MCA has made it clear that the circular does not extend the statutory time for holding AGMs. Companies that did not hold their AGM on time remain liable under the Companies Act, 2013.
Are normal ROC filing fees also waived?
No. Only the additional fees are relaxed. The regular filing fee based on the company’s authorised capital continues to apply.
What if I file after 31 December 2026 (AOC-4) or 31 January 2027 (MGT-7)?
All applicable fees, including additional fees, will be charged from the date the filing was originally due, not from the end of the relaxation period.
Which forms are covered by the relief?
AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), MGT-7 and MGT-7A for the financial year 2025-26.
Conclusion: Plan Your FY 2025-26 ROC Filings Early
The extension is genuine relief, especially for companies still waiting on audits or dealing with portal load, but it is a fee waiver with strict edges. It does not touch the AGM deadline, it does not waive the regular filing fee, and it turns expensive quickly once the window shuts. The safest approach is to treat 31 December 2026 and 31 January 2027 as outer limits rather than targets, and get your filings done well before them.
Need help getting AOC-4 and MGT-7 filed accurately and on time? Talk to the Kanakkupillai compliance team, and we will take it from there.
Source: MCA General Circular 05/2026
Ministry of Corporate Affairs, General Circular No. 05/2026 dated 24 October 2026: https://www.mca.gov.in/bin/dms/getdocument?mds=41zm4eswO3dQoa4liLFfOw%253D%253D&type=open
