ROC Compliance Calendar FY 2025-26: Complete Due Dates for CA & CS Firms

The FY 2025-26 ROC calendar at a glance

Every private limited company, LLP, OPC and public company in India carries a fixed set of MCA filing obligations each year, and missing any one of them — AOC-4, MGT-7, DIR-3 KYC, or an event-based form like MGT-14 — triggers a penalty that starts accruing the day after the deadline, in most cases with no upper cap. This calendar lays out every recurring obligation for FY 2025-26 in one place, with due dates, penalties, and which company types each applies to.

For a CA or CS firm managing dozens of corporate clients, ROC compliance is where reputations are won or lost. A late AOC-4 or MGT-7 attracts an additional fee of ₹100 per day, with no upper cap — a filing that's 90 days late can cost the client ₹9,000 in additional fees alone, on top of your professional fees. With MCA21 v3.0 now fully operational, the portal auto-flags overdue filings and cross-references them against a company's active status, so these lapses are increasingly visible to banks and counterparties doing due diligence.

Annual filing obligations for Private, Public and Section 8 companies

The bulk of ROC compliance work each year centers on the annual filing cycle, anchored to the Annual General Meeting date. For companies holding their AGM by the standard 30 September deadline, the key filings and their due dates are:

Missing any of these doesn't just mean a late fee — it can trigger a 'default' flag on the MCA master data of the company, which shows up in due diligence searches by banks, investors, and other stakeholders.

LLP filings run on a separate calendar

LLPs don't file AOC-4 or MGT-7 at all — their annual compliance runs through two LLP-specific forms instead: Form 11 (Annual Return), due by 30 May every year regardless of business activity, and Form 8 (Statement of Account & Solvency), due by 30 October. Both carry the same ₹100/day, no-cap penalty structure as company filings, which means a dormant LLP that skips filing 'because there was no activity' still accumulates the same daily fee as an active one.

Event-based filings firms often forget

Unlike annual filings, event-based forms don't appear on a calendar automatically — they're triggered by something happening in the business. The most commonly missed ones include MGT-14 (filing of board/shareholder resolutions, due within 30 days of passing), BEN-2 (significant beneficial owner declarations, due within 30 days of receiving a BEN-1), and INC-20A (declaration of commencement of business, due within 180 days of incorporation for companies with share capital).

The challenge with event-based filings isn't knowing the due date — it's knowing that the event happened at all. This is precisely where firms relying on WhatsApp updates from clients fall behind: a client opens a new bank account, passes a board resolution, or receives an SBO declaration, and unless someone proactively asks, the CS team doesn't find out until the next audit cycle.

Worked example: a company incorporated mid-year

Rajputana Foods Pvt Ltd was incorporated on 15 August 2025 with paid-up share capital. Here's how its first-year ROC calendar actually plays out:

• INC-20A (commencement of business) is due within 180 days of incorporation — by 11 February 2026 — since the company has share capital.
• Its first AGM isn't due until nine months from the end of its first financial year (which runs to 31 March 2026), giving it until 31 December 2026, later than the usual 30 September date that applies from the second year onward.
• DIR-3 KYC still applies to each of its directors by 30 September 2026 if they held a DIN as of 31 March 2026 — this deadline is independent of the company's own incorporation date.
• DPT-3, if applicable, and MSME-1, if the company has MSME creditors, follow the standard fixed dates regardless of incorporation timing.

The most common error CS teams make with newly incorporated companies is assuming the standard 30 September AGM deadline applies from year one — it doesn't, and treating it as if it does can lead to an unnecessarily rushed (or, worse, genuinely late) first AGM.

Common mistakes firms make with ROC compliance

• Missing INC-20A because it's tracked as a 'one-time' item rather than added to the recurring compliance calendar for new incorporations.
• Filing ADT-1 late because the same auditor continuing doesn't feel like it needs a fresh filing — it does, every year, within 15 days of the AGM.
• Treating DIR-3 KYC as a company-level filing instead of a per-director one, which causes it to fall through the cracks for directors who serve on boards the CS team doesn't primarily manage.
• Assuming a dormant LLP is exempt from Form 11 and Form 8 — it isn't; both are due regardless of business activity.
• Discovering a BEN-2 trigger only during the next year's audit, well past its 30-day filing window.

Building a system, not just a calendar

A calendar tells you what's due. It doesn't tell you who's responsible, what stage the filing is at, or whether the client has sent the documents you need. That's the gap between a static compliance calendar and a working compliance system — and it's the difference between finding out about a missed DIR-3 KYC from the MCA portal versus finding out from your own dashboard three weeks before the deadline.

If you're managing this across more than a handful of clients, a recurring task engine that automatically generates these obligations per client, assigns them to your team, and reminds everyone — including the client — well ahead of the deadline removes this entire category of risk. That's exactly the problem PracticeFlow was built to solve for growing CA and CS practices.