ROC Compliance Calendar

The AGM cascade — why one date drives three filings

Most ROC due dates aren't fixed calendar dates — they're computed relative to your AGM. For an AGM held on 30 September 2026: AOC-4 is due 30 days later (30 October 2026), MGT-7 is due 60 days later (29 November 2026), and ADT-1 — where an auditor was appointed or reappointed at that AGM — is due just 15 days later. Move the AGM date, and all three move with it.

This is the single biggest structural difference from a fixed compliance calendar: a company that holds its AGM earlier than the standard 30 September deadline has an earlier AOC-4/MGT-7/ADT-1 deadline too, not the commonly quoted 30 October/29 November dates. Missing the AGM deadline itself doesn't just carry its own Section 99 penalty — it makes every downstream filing that cascades from it immediately overdue as well.

The AGM itself must be held within 6 months of the financial year end — by 30 September for a standard 31 March year end, or within 9 months of the first financial year end for a company's very first AGM. An extension of up to 3 months is available on application, but it extends only the AGM deadline itself, not the AOC-4/MGT-7/ADT-1 windows that follow — those still run from whatever date the AGM is actually held.

Fixed-date filings, independent of the AGM

DPT-3 (30 June) and MSME-1 (30 April and 31 October, half-yearly) don't move with your AGM — they're fixed dates every year regardless of when the AGM happens. This makes them easy to plan around, but also easy to overlook precisely because they don't cluster with the September-November AGM season most firms build their calendar around.

LLPs have an entirely separate, fixed-date set — Form 11 (30 May, annual return) and Form 8 (30 October, statement of account and solvency) — with no AOC-4, MGT-7 or AGM concept at all. Both are required even for an LLP with zero business activity during the year; 'dormant' is not the same as 'exempt' under either form.

Two more filings sit outside both the AGM-relative and fixed-date buckets entirely: MGT-14 is event-based, triggered by specific board or shareholder resolutions rather than any date on a calendar, and INC-20A is a one-time, post-incorporation filing rather than a recurring annual one — both need a process trigger to catch, not a calendar reminder.

ADT-1 isn't automatic every year — and DPT-3 isn't optional

ADT-1 is triggered only when an auditor is actually appointed or reappointed at that specific AGM — under the standard 5-year appointment cycle, most AGMs have no ADT-1 at all. This calculator defaults the ADT-1 trigger to unticked for exactly that reason; ticking it on for every AGM by default would hand the majority of companies a filing they don't owe.

DPT-3 runs the opposite way: it's included by default for every company, because virtually every company files it — including a nil return where there are no deposits or loans, since the form also captures exempted particulars like director loans that don't look like classic 'deposits' at first glance. An explicit override excludes it, rather than requiring an opt-in tick that most users would never find.

The ₹100/day penalty, with no upper cap

AOC-4, MGT-7/7A, ADT-1 and the equivalent LLP forms all carry a ₹100/day additional fee with no upper cap, effective 1 July 2018 — a filing 78 days late costs ₹7,800 in additional fees alone, and the number keeps growing for as long as the form remains unfiled. DPT-3 and MSME-1's exact penalty figures vary by source and are flagged here for verification rather than quoted as settled fact.

Director disqualification and company strike-off

Beyond the daily fee, two more severe consequences apply to sustained non-compliance rather than a single missed filing: director disqualification (a 5-year bar from directorship in any company) follows three consecutive years of AOC-4/MGT-7 default under Section 164(2), while company strike-off under Section 248 follows two consecutive years of non-filing — a materially different, harder-to-reverse outcome than the accruing late fee.

Entity-type differences that a generic calculator gets wrong

OPCs have no AGM — their AOC-4 (180 days from financial year end) and MGT-7A (60 days from financial year end) run on the financial year end instead, a structurally different clock from AGM-relative companies. Small companies (paid-up capital ≤ ₹10 crore, turnover ≤ ₹100 crore) file the abridged MGT-7A on the same AGM-relative timeline as a standard private company. LLPs are a completely different form set, not a filtered version of the company list. ROC compliance is governed centrally by the Companies Act, with no state-specific variation — unlike GST.

AOC-4 XBRL is a format variant, not a separate deadline — it applies to listed companies, their subsidiaries, and companies crossing the paid-up capital (≥ ₹5 crore) or turnover (≥ ₹100 crore) threshold, on the identical 30-days-from-AGM clock as plain AOC-4. Both thresholds are worth re-checking every year rather than assumed to carry forward unchanged as a company grows.

Common mistakes

Tracking AOC-4/MGT-7/ADT-1 against a fixed calendar date instead of the actual AGM date is the single most common error. The second is assuming ADT-1 applies at every AGM rather than only the year an auditor is appointed or reappointed. The third is treating LLP as a filtered company checklist rather than its own distinct form set. The fourth is missing that INC-20A and MGT-14 are one-time/event-based filings that don't fit an annual-cycle calendar at all.

Frequently asked questions