AOC-4 and MGT-7 Due Date Extended for FY 2025-26: MCA Circular 05/2026 Explained

AOC-4 and MGT-7 Due Date Extended for FY 2025-26: MCA Circular 05/2026 Explained

The AOC-4 and MGT-7 due date has been extended for FY 2025-26. Through General Circular No. 05/2026 dated 24 October 2026, the Ministry of Corporate Affairs (MCA) has allowed companies to file financial statements (AOC-4 and its variants) up to 31 December 2026 and annual returns (MGT-7 and MGT-7A) up to 31 January 2027, without paying additional fees.

The relief is narrower than it looks. It waives additional fees on two sets of ROC forms. It does not extend the time for holding the Annual General Meeting (AGM), and it does not cover other ROC forms. Here is what company secretaries, CFOs and CA firms need to know.

What MCA General Circular 05/2026 says

MCA issued the circular after representations from stakeholders seeking more time for annual filings under the Companies Act, 2013. The relief applies to filings for FY 2025-26.

Two conditions in the circular matter most:

• No AGM extension. The circular says it shall not be construed as extending the statutory time for holding AGMs. Companies that missed the AGM timeline remain liable under the Act.
• Miss the extended date, pay from the original date. If a form is filed after the relaxation period, all fees, including additional fees under the Companies (Registration Offices and Fees) Rules, 2014, apply from the original due date under the Act, not from the extended date.

Normal due dates vs extended dates

For a company with a 31 March year-end, the AGM had to be held by 30 September 2026 under Section 96 (unless the Registrar granted an extension). The normal filing dates run from the AGM date.

The extended dates are fixed. They do not move with the company's actual AGM date. Companies whose window had already closed before 24 October 2026, such as OPCs, can still file without additional fees by the extended date.

Where the Registrar has extended a company's AGM and the statutory filing date falls after the extended date in the circular, the statutory date applies.

What the extension does not cover

• AGM default. A late AGM without a Registrar's extension is still a default under Section 96. Under Section 99, the company and every officer in default can face a fine of up to ₹1 lakh, plus up to ₹5,000 per day for a continuing default.
• Penalties under Sections 92(5) and 137(3). The circular waives additional fees only. It does not mention these penalties.
• Other ROC forms. ADT-1, MGT-14, DPT-3, MSME-1 and DIR-12 keep their normal timelines and fees.
• Earlier years. Pending AOC-4 or MGT-7 filings for FY 2024-25 or earlier are not covered.
• Fees already paid. The circular has no refund provision for additional fees paid before 24 October 2026.

The cost of missing the extended date

Additional fees under the Fees Rules are ₹100 per day per form, with no upper cap. Because the fee runs from the original due date if you miss the extended date, a short delay costs far more than it seems.

For example, if MGT-7 is filed on 10 February 2027, ten days after the extended date, the additional fee is counted from 29 November 2026. That is 73 days, or ₹7,300 for one form, instead of ₹1,000 for ten days.

Action checklist for companies and CA firms

How Figment's tools help

Figment does not file ROC forms, but these tools help around annual filing season.

• Compliance Calendar 2026-27: a free calendar of statutory due dates across income tax and TDS, GST, PF and ESI, and ROC/MCA. Each date can be saved to Google, Outlook or Apple Calendar with a reminder two days before, and the list can be downloaded as a PDF.
• MCA strike-off check: explains how to read a company's or LLP's MCA status (Active, Active Non-Compliant, Strike Off and others). Companies that keep missing annual filings can end up marked Active Non-Compliant or face strike-off, so finance teams use this to screen vendors and customers. Figment also offers bulk status screening and a Company Verification API.
• VenCPC: Figment's vendor master tool validates vendor PAN, GSTIN and MSME status, alongside company status checks.

Key takeaways

• MCA General Circular 05/2026 (24 October 2026) lets companies file AOC-4 by 31 December 2026 and MGT-7/7A by 31 January 2027 without additional fees.
• It waives additional fees only. AGM timelines and penalties are unchanged.
• Miss the extended date, and additional fees run from the original due date.
• Other ROC forms and earlier years are not covered.