ROC Compliance: The Silent Risk That Can Cost You Your Directorship
Many company directors don’t realise that missing ROC filing deadlines can lead to penalties of up to ₹1 lakh per form, additional fees of ₹100/day for delays, and even disqualification from directorship. With the MCA’s shift to fully digital filing, there are no more excuses for late submissions.
Limited-Time Relief: CCFS-2026 Ends September 15, 2026
New for September 2026: If you have pending or delayed filings, the MCA’s Companies Compliance Facilitation Scheme 2026 (CCFS-2026) is a limited-window opportunity to regularise defaults at a fraction of the normal cost:
- 💰 90% waiver of additional fees: pay the normal fee plus just 10% of the additional fees on delayed filings such as AOC-4, MGT-7, MGT-7A, and ADT-1
- 😴 Dormancy relief: 50% concession on MSC-1 applications to move your company to dormant status
- 🚪 Strike-off relief: 75% concession on STK-2 (voluntary closure) fees — reduced to about ₹2,500 from ₹10,000
Act fast: the scheme’s validity has been extended to September 15, 2026 — after that, full additional fees apply again. If you have years of pending filings, this is the cheapest regularisation window you’ll get.
Critical Filing Calendar — FY 2026-27
| Form | Purpose | Due Date |
|---|---|---|
| ADT-1 | Appointment of Auditor | Within 15 days of AGM |
| AOC-4 / AOC-4 CFS | Financial Statements | Within 30 days of AGM |
| MGT-7 / MGT-7A | Annual Return | Within 60 days of AGM |
| MGT-14 | Board Resolutions | Within 30 days of Board Meeting |
| DIR-3 KYC | Director KYC | Once every 3 years (as per 2025 amendment) |
| MSME-1 | Outstanding MSME Payments | Half-yearly (October & April) |
| DPT-3 | Return of Deposits | June 30 |
| BEN-2 | Significant Beneficial Ownership | Within 30 days of receipt of BEN-1 |
AGM-Related Deadlines
- AGM must be held within 6 months from the end of the financial year (by September 30 for March year-end companies)
- Board Meeting to approve financial statements: Before the AGM
- First Board Meeting of the year: Within 30 days of incorporation (new companies) or as scheduled
- Minimum Board Meetings: 4 per year (2 for Small Companies)
Digital Filing — What Changed in 2025
As of July 2025, the following forms must be filed electronically only:
- AOC-1, AOC-2, AOC-4
- MGT-7, MGT-7A
- ADT-1 to ADT-4
- GNL-1
Penalty Structure for Delayed Filing
| Delay Period | Additional Fees |
|---|---|
| Up to 30 days | 2x normal fees |
| 30-60 days | 4x normal fees |
| 60-90 days | 6x normal fees |
| 90-180 days | 10x normal fees |
| Beyond 180 days | 12x normal fees |
Pro Tips for Never Missing a Deadline
- 📅 Set automated calendar reminders for every filing deadline
- 🤖 Use compliance management software with alert features
- 👨💼 Appoint a dedicated compliance officer or outsource to professionals
- 📋 Maintain a rolling checklist that gets reviewed monthly
- ⏳ Already delayed? Use CCFS-2026 before September 15, 2026 instead of paying 12x fees
Don’t risk penalties. SmartAITax’s company compliance services ensure every filing is submitted on time, every time.
