AOC-4 and MGT-7 extension FY 2025-26: new MCA filing windows
The Ministry of Corporate Affairs (MCA) has allowed companies to file their FY 2025-26 financial statements in Form AOC-4 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 relief comes through General Circular No. 05/2026 dated 24 October 2026. It does not extend the time limit for holding the annual general meeting (AGM).
What does MCA General Circular 05/2026 say?
MCA issued the circular after receiving representations from stakeholders seeking more time for annual filings under the Companies Act, 2013 for FY 2025-26. Companies may now file the following forms within the windows below without additional fees:
| Form | What it is used for | File without additional fees up to |
|---|---|---|
| AOC-4 | Standalone financial statements | 31 December 2026 |
| AOC-4 (CFS) | Consolidated financial statements | 31 December 2026 |
| AOC-4 (XBRL) | Financial statements in XBRL format | 31 December 2026 |
| AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) | Financial statements of NBFCs following Ind AS | 31 December 2026 |
| MGT-7 | Annual return | 31 January 2027 |
| MGT-7A | Annual return of One Person Companies and small companies | 31 January 2027 |
What were the normal due dates for FY 2025-26?
Under the Companies Act, 2013, a company (other than a One Person Company) must generally hold its AGM within six months from the end of the financial year. Financial statements are filed within 30 days of the AGM and the annual return within 60 days of the AGM. A One Person Company files its financial statements within 180 days from the end of the financial year.
For a company with a 31 March year-end that held its AGM on 30 September 2026, the position is:
| Form | Normal last date | Without additional fees under the circular |
|---|---|---|
| AOC-4 series | 30 October 2026 | 31 December 2026 |
| MGT-7 / MGT-7A | 29 November 2026 | 31 January 2027 |
| AOC-4 of an OPC | 27 September 2026 | 31 December 2026 |
If the AGM was held earlier, the normal due dates fall earlier too, but the relaxation runs to the same dates for all companies.
Is the AGM deadline also extended?
No. Paragraph 3 of the circular makes it clear that it does not extend the statutory time for holding AGMs. Companies that have not held their AGM within the time allowed by the Act remain liable under the relevant provisions. The relief is limited to the additional fees on filing the forms with the Registrar of Companies.
A company that has not yet held its AGM for FY 2025-26 should therefore treat the AGM as a separate compliance. Delayed filing of AOC-4 and MGT-7 without additional fees does not regularise a delayed AGM.
What happens if the forms are filed after the extended dates?
Paragraph 4 of the circular states that filings made after the relaxation period attract all fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014. Importantly, the additional fees are counted from the date the filing was originally due under the Act, not from 31 December 2026 or 31 January 2027.
In simple terms, missing the extended window means losing the benefit of the circular entirely. The additional fee for annual filing forms is levied per day of delay, so a company that files AOC-4 even a few days after 31 December 2026 pays for the whole delay counted from its original due date.
Who is covered, and who is not?
The circular is addressed to companies registered under the Companies Act, 2013, including private, public, One Person, small and NBFC companies filing the forms listed above. It covers only FY 2025-26 filings.
It does not cover:
- LLPs: LLP Form 8 (Statement of Account and Solvency) and Form 11 (Annual Return) are filed under the LLP Act, 2008 and are not mentioned in the circular. See LLP Form 8 due date and late fee for FY 2025-26.
- Earlier years: Pending filings for FY 2024-25 or earlier are not part of this relaxation.
- Other event-based forms: Forms such as ADT-1 (auditor appointment) or MGT-14 (filing of resolutions) are not listed in the circular.
What should companies do now?
The extra time is best used to complete filings properly rather than to defer them. A practical sequence:
- Confirm that the AGM for FY 2025-26 was held within time, and keep the notice, minutes and attendance records in order.
- Finalise the audited financial statements, Board's report and auditor's report, and check that the XBRL requirement (where applicable) is met.
- File the AOC-4 series well before 31 December 2026, as the MCA portal is usually heavily used near any deadline.
- Prepare MGT-7 or MGT-7A using the shareholding and director details as on the year-end, and file it before 31 January 2027.
- Make sure the Digital Signature Certificates of the signing director and professional are valid on the date of filing.
Companies that want a single view of all annual ROC due dates can refer to our annual ROC compliance page.
The information in this article reflects the law as on the date of publication and is for general guidance only.
CA. Kunal Darwani
Frequently asked questions
Does the MCA circular also extend the LLP Form 8 or Form 11 due date?
No. General Circular 05/2026 is addressed to companies and covers only the AOC-4 series and MGT-7/MGT-7A under the Companies Act, 2013. LLP forms are governed by the LLP Act, 2008 and are not mentioned in it.
Can a One Person Company use the extended window for AOC-4?
The circular applies to the financial statements of companies for FY 2025-26 filed in the AOC-4 series, without carving out any class. An OPC can therefore file AOC-4 for FY 2025-26 by 31 December 2026 without additional fees.
Is the normal filing fee still payable within the extended window?
Yes. The circular waives only the additional fees for late filing. The normal filing fee under the Companies (Registration Offices and Fees) Rules, 2014, which depends on the company's share capital, remains payable.
What happens if AOC-4 is filed after 31 December 2026?
The relaxation ends. Additional fees become payable and, as the circular states, are counted from the date the form was originally due under the Act, not from 31 December 2026.