AOC-4, MGT-7 Due Date Extended: MCA Circular 05/2026 Explained
October 31, 2026 · Other News Alerts / Articles
AOC-4, MGT-7 due date extended for FY 2025-26: AOC-4 by December 31, 2026 and MGT-7/7A by January 31, 2027. The AGM deadline is not extended.
AOC-4, MGT-7 due date extended: the Ministry of Corporate Affairs (MCA), by General Circular No. 05/2026 dated October 24, 2026, allows companies to file FY 2025-26 financial statements up to December 31, 2026 and annual returns up to January 31, 2027 without additional fees. It affects every company, including small companies and One Person Companies (OPCs).
The catch: the annual general meeting (AGM) deadline is not extended, and filings after the new dates pay additional fees from the original due date. The accompanying presentation walks through each date, as of October 31, 2026.
AOC-4, MGT-7 due date extended: what MCA General Circular 05/2026 says
Financial statements: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) for FY 2025-26 can be filed up to December 31, 2026 .
Annual returns: MGT-7 and MGT-7A for FY 2025-26 can be filed up to January 31, 2027 .
What is waived: only additional fees. Normal filing fees remain payable.
Myth vs fact
Myth
Fact
The AGM deadline is also extended.
No. Paragraph 3 says the statutory time for holding AGMs is not extended.
A late filing pays additional fees only from the extended date.
No. Paragraph 4 counts all fees, including additional fees, from the date the filing was actually due under the Act.
Small companies and OPCs are left out.
No. MGT-7A, the abridged annual return for OPCs and small companies, is covered.
Deadline timeline: AOC-4 due date FY 2025-26 and MGT-7 dates
Section 96 of the Companies Act, 2013 requires the AGM within six months of the year-end, unless the Registrar extends it; OPCs need not hold one. The table assumes a March 31 year-end and an AGM on September 30, 2026.
Item
Original due date
Extended date without additional fees
AGM (section 96)
September 30, 2026
Not extended
AOC-4 for an OPC (section 137, 180 days from year-end)
September 27, 2026
December 31, 2026
AOC-4 and variants (section 137, 30 days from AGM)
October 30, 2026
December 31, 2026
MGT-7 and MGT-7A (section 92(4), 60 days from AGM)
November 29, 2026
January 31, 2027
An earlier AGM means earlier original dates, but the same extended dates. Where no AGM was held, sections 92 and 137 count from the date it should have been held.
Additional fees for ROC annual filing after the extended dates
Section 403 of the Companies Act, 2013 permits late filing on payment of an additional fee. For forms under sections 92 and 137, the Companies (Registration Offices and Fees) Rules, 2014 prescribe an additional fee of INR 100/- per day of delay, with no upper limit .
Example: an AOC-4 due on October 30, 2026 but filed on January 10, 2027 is 72 days late (October 31, 2026 to January 10, 2027), so the additional fee is INR 7,200/-, not INR 1,000/- for 10 days. Additional fees are separate from penalties under sections 92(5) and 137(3). The circular deals only with additional fees; it does not amend the due dates in sections 92 and 137.
3 things to do this week
Check the AGM date. A late FY 2025-26 AGM is not cured by this circular.
Fix internal dates well before December 31, 2026 and January 31, 2027.
Confirm the correct form. AOC-4, CFS, XBRL or NBFC (Ind AS) variant; MGT-7 or MGT-7A.
For the income-tax deadline, see the ITR due date November 21, 2026 checklist for firms, LLPs and companies .
Frequently asked questions
What is the AOC-4 due date for FY 2025-26 after the extension?
December 31, 2026, without additional fees, for AOC-4 and every listed variant.
What is the MGT-7A due date for FY 2025-26?
January 31, 2027, the same as MGT-7.
Does MCA General Circular 05/2026 extend the AGM date?
No. Paragraph 3 keeps the statutory AGM time unchanged.
What if a company files after the extended dates?
All fees, including additional fees, apply from the original due date under the Act.
Sources
MCA General Circular No. 05/2026 dated October 24, 2026
Companies Act, 2013, sections 92, 96, 137 and 403 (India Code)
Companies (Registration Offices and Fees) Rules, 2014 (MCA rules page)
This article is for general information only and does not constitute professional advice.