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ROC Late Filing Penalty

Most ROC annual filings — AOC-4, MGT-7/7A, ADT-1, LLP Form 11 and Form 8 — carry a flat ₹100-per-day penalty with no upper cap. A filing 78 days late costs ₹7,800 in additional fees alone, and that number never stops growing until the form is filed.

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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Why 'no upper cap' is the detail that matters most

Unlike many statutory penalties that plateau at a fixed maximum, the ₹100/day additional fee for AOC-4, MGT-7/7A, ADT-1 and the equivalent LLP forms has no ceiling — it simply keeps accruing for as long as the filing remains outstanding. A filing 78 days late costs ₹7,800; the same filing left for a full year would cost roughly ₹36,500, and there's no point at which it stops growing on its own.

This is a deliberate design choice, effective from 1 July 2018 — it's meant to make delay progressively more expensive so that catching a missed filing early carries a genuinely different cost than catching it months later, rather than a flat penalty that's the same whether you're a day late or a year late.

Not every ROC penalty is uncapped

DIR-3 KYC breaks this pattern — its penalty is a flat ₹5,000 to reactivate a deactivated DIN, regardless of how long the DIN stayed deactivated, not a daily-accruing figure. Other filings like DPT-3, MSME-1 and INC-20A carry their own separate penalty structures (some involving a fixed amount plus per-officer or per-day components) that we flag as needing case-by-case confirmation rather than presenting a single blanket figure, since the exact amounts vary by form and haven't all been confirmed to the same standard as the AOC-4/MGT-7 ₹100/day rule.

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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