AOC-4, XBRL, CFS, MGT-7 or MGT-7A: Which Annual Form Must You File for FY 2025-26?

General Circular 05/2026 names seven forms. Five of them belong to the AOC-4 family and carry a fee-free window up to 31 December 2026: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS). The other two, MGT-7 and MGT-7A, carry a window up to 31 January 2027. The relief applies to FY 2025-26 only and covers additional fees, not the normal filing fee.

With the extra weeks, the temptation is to start late. But the first task is not to file anything. It is to be sure which form your company is actually required to file. Using the wrong variant leads to rejected filings, wasted fees and, in the worst case, a form that has to be redone after the window has closed. Since fees after the window are counted from the original due date, a wrong-form mistake in late December can be expensive.

The good news is that the form is decided by a handful of facts about the company, and you can usually work it out in a couple of minutes. The finder below asks those questions in order, hides the ones that do not apply to you, and ends with the two forms you should expect to file.

Treat the result as a starting point. It uses the criteria that public references describe, and it assumes you have answered each question accurately. Where you chose “not sure” on the small company question, settle that first, because it decides between the full annual return and the shorter one. Your Company Secretary can confirm it from your paid-up capital and turnover in a few minutes.

XBRL stands for eXtensible Business Reporting Language. In practice it means that the numbers in the balance sheet, profit and loss account and notes are tagged to a standard taxonomy, so that the data can be read by machines and not only by people. A company that falls within the XBRL rules must file the financial statements in that format, using the AOC-4 XBRL variant.

As public references summarise the rules, XBRL filing is required for listed companies and their Indian subsidiaries, for companies with paid-up capital of ₹5 crore or more or turnover of ₹100 crore or more, and for companies that must follow Ind AS. Non-banking finance companies, housing finance companies and companies engaged in banking or insurance are described as exempt unless the MCA notifies otherwise. The references also say that a company outside the mandatory categories can file in XBRL voluntarily, and that once it does, its later filings are expected to follow the same format.

A company that has subsidiaries, associates or joint ventures is generally required to prepare consolidated financial statements, in addition to its own standalone statements. Those are filed in AOC-4 CFS. They are a separate filing from the standalone AOC-4, with their own attachments, and, as reported, their own additional fee count if filed late.

NBFCs that follow Ind AS use their own forms, AOC-4 NBFC (Ind AS) for the standalone statements and AOC-4 CFS NBFC (Ind AS) for the consolidated ones. The circular names both, which is a useful reminder that the relief is not limited to the ordinary AOC-4. If you are an NBFC that does not follow Ind AS, the references suggest that the standard AOC-4 applies, but you should confirm it with your CA.

One practical point for groups: the consolidated statements depend on the subsidiaries' accounts. If a subsidiary is late with its audit, the parent is late with the consolidation, and the fee clock on the parent is running while it waits. Set the subsidiary deadline earlier than the parent deadline, and review it weekly in the last month.

The annual return is the company's record of its structure and people for the year: registered office, directors and key managerial personnel, shareholders and shareholding changes, meetings held and attendance, remuneration and the status of charges and loans. It is filed on MGT-7 for most companies and on the simpler MGT-7A for One Person Companies and small companies.

The difference is real. MGT-7A asks for less, which makes it faster to prepare and cheaper to review. But the classification matters: a company that is not a small company cannot use MGT-7A just because it would prefer to. The classification follows the definition in Section 2(85) and the limits in force, which the Ministry has changed from time to time, so check the current limits with your CS before you decide.

Companies above certain size or listing thresholds are also expected to have the annual return certified by a practising Company Secretary. The thresholds are set in the rules and should be confirmed by your CS, because they decide whether you need that certification before the MGT-7 can be filed.

Each form comes with its own bundle of documents. The details differ by company, so the tabs below show the typical attachments and what to prepare ahead of time. Your CA or CS will give you the exact list.

The practical rule is that every figure and date in the forms should be traceable to a signed document. If the AGM date on the form, in the minutes and in the board's report do not agree, the filing is at risk of being returned, and a return in the last week of the window is the situation you want to avoid.

A rejection costs time, and when the window is about to close it can cost money. These are the problems we see most often. Open each one to see the fix.

If you would like a second pair of eyes before you submit, our team can review the package, confirm the form variant and file it for you. See our Annual ROC Compliance service, or read what the circular means in our Circular 05/2026 guide.

Run through the list below once the form is ready. Each tick is a rejection or a late fee you have avoided.

If you can tick every line, you are in good shape. If several are open, the extra weeks the circular gave you are probably the right amount of time to close them, as long as you start now.