The Ministry of Corporate Affairs (MCA) has extended the timelines for filing annual financial statements and annual returns for the financial year 2025-26, providing relief from additional filing fees. Under General Circular No. 05/2026 dated 24 October 2026, eligible companies can complete the specified annual ROC filings within the revised deadlines without paying additional fees.

1. Revised Due Dates for Annual Company Filings

The extended deadlines announced by the MCA are as follows:

A. Financial Statements – Due Date: 31 December 2026

Companies can file the following e-forms for FY 2025-26 up to 31 December 2026 without additional fees:

• AOC-4 – Filing of financial statements.

• AOC-4 CFS – Filing of consolidated financial statements.

• AOC-4 XBRL – Filing of financial statements in XBRL format.

• AOC-4 NBFC (Ind AS) – Financial statements for applicable NBFCs.

• AOC-4 CFS NBFC (Ind AS) – Consolidated financial statements for applicable NBFCs.

B. Annual Returns – Due Date: 31 January 2027

The MCA has also extended the filing deadline for the following annual return forms for FY 2025-26:

• MGT-7 – Annual return for applicable companies.

• MGT-7A – Abridged annual return for eligible One Person Companies (OPCs) and small companies.

Both forms can be filed up to 31 January 2027 without additional fees.

2. No Additional Fees Within the Extended Period

Companies filing the above forms within their respective extended deadlines will not be required to pay additional filing fees under this relaxation. This provides businesses with additional time to finalise financial statements, complete annual return disclosures and fulfil their ROC filing requirements.

However, companies should ensure that the forms are accurate, complete and supported by the necessary records before submission.

3. Important Clarification: AGM Due Dates Remain Unchanged

The MCA has expressly clarified that the circular does not extend the statutory timelines for holding Annual General Meetings (AGMs).

Companies that have failed to hold their AGMs within the applicable statutory timelines remain liable under the relevant provisions of the Companies Act, 2013. The filing extension should not be treated as a waiver of AGM-related compliance obligations.

4. What Happens If You Miss the Extended Deadline?

Companies filing the specified forms after the applicable extended deadline will be liable to pay the applicable filing fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014.

Importantly, the additional fees will be calculated with reference to the original statutory due date under the Companies Act, 2013, and not merely from the end of the extended period.

5. What Should Companies Do Now?

Companies should use the additional time to complete their annual compliance requirements efficiently. Key steps include:

• Finalise and approve the financial statements and related reports.

• Complete the applicable AOC-4 filing.

• Prepare and verify the annual return in MGT-7 or MGT-7A, as applicable.

• Check AGM compliance separately and address any delay under the applicable law.

• Submit the relevant forms well before the extended deadlines to avoid last-minute portal or filing issues.

Conclusion

MCA General Circular No. 05/2026 dated 24 October 2026 provides important relief for annual financial statement and annual return filings for FY 2025-26. The revised deadlines are 31 December 2026 for the specified AOC-4 forms and 31 January 2027 for MGT-7 and MGT-7A. However, the extension does not change AGM timelines, and filings made after the relaxed deadlines may attract additional fees calculated from the original statutory due dates.

Companies should review their compliance status and plan their filings accordingly.

For expert guidance on this topic, contact your tax professional today.