MCA Extends AOC-4 to 31 December 2026, MGT-7 to 31 January 2027: What It Really Means

On Saturday, 24 October 2026, the Ministry of Corporate Affairs issued General Circular No. 05/2026 (File No. Policy-17/111/2022-CL-V-MCA), signed by the Deputy Director (Policy) and addressed to the DGCoA, all Regional Directors, all Registrars of Companies and all stakeholders. The stated reason is simple: the Ministry received representations from stakeholders asking for more time to file the annual statutory forms for financial year 2025-26.

The decision, set out in paragraph 2, has two parts. Companies may file the financial statements in AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) up to 31 December 2026. And they may file the annual return in MGT-7 and MGT-7A up to 31 January 2027. In both cases the filing is allowed “without payment of additional fees”.

Read that last phrase carefully, because it is where most of the confusion will come from. The relief is about additional fees, the daily late charge. It is not a waiver of the normal filing fee that every company pays on every filing, and it is not a general amnesty for other defaults. It is also a relaxation for a single financial year. Earlier years that are still pending are not covered by this circular.

The circular names seven forms: the five AOC-4 variants and the two annual return forms. Anything that is not on that list should be assumed to be outside the relief until your Company Secretary or CA confirms otherwise. Tap through the common ones to see where each stands.

The practical point is that an annual compliance cycle is rarely just two forms. Most companies also deal with the auditor appointment filing (ADT-1), the half-yearly MSME return, director KYC, and, for some, the deposits return. None of these is named in the circular, so each keeps its own date and its own late fee. A company that reads “MCA extended the deadline” in a headline and stops there can easily miss one of them.

Director KYC deserves a special mention. A director whose KYC lapses sees the DIN deactivated, and a director with a deactivated DIN can run into trouble signing and filing the very forms the circular is trying to help you file. Check KYC status before you start, not after the AOC-4 is stuck.

The original due dates are not fixed calendar dates. They run from your AGM. The financial statements are due within 30 days of the AGM, and the annual return within 60 days of the AGM. A company that held its AGM on 30 September 2026 would therefore have faced 30 October 2026 for the AOC-4 and 29 November 2026 for the MGT-7. The circular pushes those to 31 December 2026 and 31 January 2027.

If your AGM was held earlier or later, your original dates were different. Enter your AGM date and the tool shows the normal due date, the relief date, and where each stands against today.

One more subtlety. The relief is a date up to which no additional fee is charged. It was never designed to shorten anyone's time. If your own AGM-based due date is later than the relief date, for example because the AGM was held in December, the tool shows the later date. This is our reading of how the relief interacts with the normal timelines, so confirm it for your own case.

It helps to see the whole sequence on one line. The AGM date is the foundation, because every other date hangs from it. The circular then sits on top of the original dates and moves the fee-free point further out, but only for the two form families.

Two windows, two dates. The January date applies to the annual return only. A company that files its MGT-7 on 15 January but has not yet filed its AOC-4 has not used the January window for the accounts. The AOC-4 relief ended on 31 December.

Paragraph 3 of the circular is short but important. It says the circular should not be construed as conferring any extension of statutory time for holding AGMs, and that companies which have not adhered to the relevant statutory timelines remain liable under the relevant provisions of the Act. The circular does not name those provisions.

As public references summarise the position, a company must hold its AGM within six months of the close of the financial year, which for FY 2025-26 meant by 30 September 2026, and the gap between two AGMs must not exceed 15 months. The Registrar may extend the time by up to three months for a special reason, but that has to be applied for, and it is not available for the first AGM. Failure to comply is reported to attract a fine of up to ₹1,00,000 on the company and on each officer in default, with a further fine of up to ₹5,000 for each day of continuing default.

There is a quieter consequence as well. Because the AOC-4 and MGT-7 timelines are counted from the AGM, a company that holds its AGM very late is moving its own filing dates later at the same time. That is a normal mechanical effect, not a benefit. The AGM default stays on the record.

Paragraph 4 is the one to circulate in your finance team. It says that any filing made after the currency of the circular attracts payment of all fees, including additional fees, as provided in the Companies (Registration Offices and Fees) Rules, 2014, from the date when such filings were actually due under the Act.

In plain words, the extension does not reset the clock. It pauses the meter. If you file inside the window, the meter never ran. If you file one day after the window, the meter is applied backwards to the original due date.

Here is a worked example using public references for the rate. Public references report the additional fee at ₹100 per day per form with no cap. Suppose a company held its AGM on 30 September 2026, so its AOC-4 was originally due on 30 October 2026. It files on 5 January 2027. That is 67 days after the original due date, so the reported additional fee would be about ₹6,700 on that form alone, even though the filing was only five days after the relief ended. The MGT-7 has its own separate calculation.

The additional fee is also not the only exposure. Late financial statements and late annual returns can carry fines on the company and officers under the Act, and long-running non-filing can lead to director disqualification and strike-off proceedings. Amounts reported by public references vary and we have not independently verified them, so we leave the numbers to your professional.

One question the circular does not answer: what happens to a company that has already filed and paid additional fees before 24 October. The circular says nothing about refunds, and the sources we reviewed do not either. Do not assume a refund. Ask your CA whether anything can be done.

An extension is a gift of time, but time has a way of vanishing. Boards that were already late on 30 October now have two more months, and the temptation is to wait. The better approach is to set an internal deadline well before the relief date, because the last week of December is also the week when auditors, signatories and portals are at their busiest.

A sensible internal target is mid-December for the AOC-4 and early January for the MGT-7. That leaves a buffer for a rejected form, a digital signature that has expired, an XBRL validation error, or a director who is travelling. Tick off the list below as you go.

If your company is behind on more than one year, or your AGM was late, or your books are not finalised, the circular is not a solution by itself. It is one input into a plan, and the plan is better drawn up with a professional who has seen the pattern before. That is exactly what our annual ROC compliance team does, and you can read how the service works on our Annual ROC Compliance page.