MCA Extends AOC-4 to 31 Dec 2026 and MGT-7 to 31 Jan 2027

The Ministry of Corporate Affairs (MCA) issued General Circular No. 05/2026 on 24 October 2026. It lets companies file their financial statements for FY 2025-26 (e-form AOC-4 and its variants) up to 31 December 2026, and their annual returns (e-forms MGT-7 and MGT-7A) up to 31 January 2027, without additional fees. The circular says it was issued after representations from various stakeholders seeking more time for the FY 2025-26 annual filings. It does not extend the time for holding an Annual General Meeting (AGM), and filings made after the relaxed dates will attract additional fees counted from the original due date.

Notification at a Glance

What Has Changed Under General Circular 05/2026?

Under the Companies Act, 2013, a company files its financial statements within 30 days of its AGM (section 137) and its annual return within 60 days of the AGM (section 92(4)). A filing made after those dates normally attracts additional fees under section 403.

For FY 2025-26, the circular relaxes those fees for a fixed window:

For a company that held its AGM on 30 September 2026, this moves the practical deadline for AOC-4 from 30 October 2026 to 31 December 2026, and for MGT-7 from 29 November 2026 to 31 January 2027.

What Does the Circular Not Change?

Three limits matter as much as the new dates:

• The AGM deadline. The circular states that it does not extend the statutory time for holding AGMs. A company that missed its AGM deadline remains liable under the Act.
• Fees after the window. If you file after 31 December 2026 (AOC-4) or 31 January 2027 (MGT-7/7A), additional fees apply in full and are counted from the original due date, not from the relaxed date.
• Other forms. The circular names only the AOC-4 and MGT-7 families. Forms it does not mention, such as ADT-1 (auditor appointment) and DIR-12, keep their own time limits. Cost audit reports are covered separately: General Circular No. 06/2026 (27 October 2026) lets companies file CRA-4 for FY 2025-26 up to 31 December 2026 without additional fees.

Who Is Affected?

• Every company filing financial statements and annual returns for FY 2025-26, including private, public and Section 8 companies, NBFCs filing in Ind AS formats, and companies filing in XBRL.
• One Person Companies and small companies that file MGT-7A.
• Companies that have already filed are not affected. The relief only removes additional fees for filings made within the window.

What Should Companies Do Now?

1. Confirm your AGM date and status. The extension helps only with filing. If your AGM is still pending, check the time limit under section 96 and any extension granted by the Registrar of Companies (ROC).
2. File what is ready. There is no benefit in waiting until December. Portal traffic usually peaks close to a deadline.
3. Fix portal access now. Check that each signatory's Digital Signature Certificate (DSC) is valid and associated with their MCA-21 V3 login.
4. Diarise the two dates. 31 December 2026 for AOC-4 and 31 January 2027 for MGT-7/7A. Missing them brings back additional fees from the original due date.
5. Check other forms separately. Confirm the due dates for ADT-1 and any other event-based filings. If your company files a cost audit report, CRA-4 has its own fee-free window to 31 December 2026 (General Circular No. 06/2026).

How Can Corpseed Help?

Corpseed's company law team prepares and files AOC-4, MGT-7 and related ROC forms, and can check whether your AGM and auditor filings are on track. Schedule a call back to get your FY 2025-26 annual filings planned within the relaxed window.

See our annual compliance service for private limited companies: https://www.corpseed.com/service/annual-compliance-for-private-limited

Key Takeaways

• MCA General Circular No. 05/2026 (24 October 2026) applies to FY 2025-26 filings only.
• AOC-4 and its variants can be filed without additional fees up to 31 December 2026.
• MGT-7 and MGT-7A can be filed without additional fees up to 31 January 2027.
• The AGM deadline is not extended, and late filings after the window pay additional fees from the original due date.
• Forms not named in the circular, such as ADT-1, keep their own time limits. CRA-4 has a separate window to 31 December 2026 under General Circular No. 06/2026.

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This article is for general information and does not constitute legal advice. Requirements can vary by state, product and facts of your case. Please verify with the official notification or speak to a Corpseed expert before acting.