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ROC Compliance for a Newly Incorporated Company

A newly incorporated company's first obligations arrive in this order: INC-20A within 180 days of incorporation (26 October 2026 in this example), then its first AGM within 9 months of the first financial year end, then AOC-4 and MGT-7 computed from that first AGM.

Company profile

Entity & dates

AOC-4, MGT-7 and ADT-1 all recompute from this date.

Applicable filings

ADT-1 is filed only when an auditor is appointed or re-appointed — typically once every five years, not at every AGM.

DPT-3 is filed by every company — including a nil return where there are no deposits or loans. Included by default; tick only to exclude it.

Event-based — 30 days from the resolution date, not annual.

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No applicable filings found for this profile — check your entity type and flags above.

Penalty estimator

E.g. AOC-4 filed 78 days late = ₹7,800.

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The sequence, for a company that's never filed anything before

INC-20A comes first and is entirely independent of the AGM — a declaration that subscribers have paid for their shares and the company can commence business, due within 180 days of incorporation. Until it's filed, the company can't fully exercise its borrowing powers.

The first AGM follows on its own separate clock — 9 months from the end of the company's first financial year, three months longer than the standard 6-month rule that applies to every AGM after. AOC-4 and MGT-7 then cascade from that first AGM date exactly as they would for an established company.

Setting up the ongoing calendar from day one

The most efficient approach for a new company is to set up its full annual filing calendar — AGM planning, AOC-4, MGT-7, DPT-3 — at the same time as tracking INC-20A, rather than treating the one-time filing as a separate task from the recurring obligations that begin immediately after it.

A new company's first DPT-3 (30 June) may arrive before its first AGM has even been planned in detail — since DPT-3 is fixed-date and independent of the AGM, it's worth flagging on the calendar from incorporation day rather than only once the AGM planning conversation starts.

Frequently asked questions

Why this matters

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Estimate for planning purposes, not legal or compliance advice — always confirm with a CS/CA before filing.

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