AOC-4 and MGT-7 due dates extended for FY 2025-26: what General Circular 05/2026 does and doesn't do

In short: by General Circular No. 05/2026 dated 24 October 2026, the Ministry of Corporate Affairs (MCA) has allowed companies to file their financial statements for FY 2025-26 (AOC-4 and its variants) up to 31 December 2026, and their annual return (MGT-7 or MGT-7A) up to 31 January 2027, without paying additional fees. The time for holding the AGM is not extended. The relief does not cover LLPs, MSME Form I or earlier financial years.

What the circular allows. Paragraph 2 of the circular permits these filings without additional fees:

• AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) for FY 2025-26: up to 31 December 2026
• MGT-7 and MGT-7A for FY 2025-26: up to 31 January 2027

What the dates would otherwise have been. Under section 137(1) of the Companies Act, 2013, financial statements are filed within 30 days of the AGM. Under section 92(4), the annual return is filed within 60 days of it. Where no AGM is held, both periods run from the last date on which the AGM should have been held. For a company with a 31 March year-end and an AGM on 30 September 2026, AOC-4 would have been due by 30 October 2026 and MGT-7 by 29 November 2026. Late filing attracts an additional fee under the Companies (Registration Offices and Fees) Rules, 2014, which for these forms has been ₹100 for each day of delay since 1 July 2018. The circular waives that fee for filings made by the new dates.

What the circular does not do: extend the AGM. Paragraph 3 makes clear that the circular is not an extension of the statutory time for holding AGMs, and that companies which have not kept to the statutory timelines remain liable under the Act. Under section 96(1), the AGM must be held within six months of the end of the financial year (30 September for a 31 March year-end), or within nine months for the first AGM. The Registrar can extend this by up to three months for a special reason, though not for the first AGM, and the application in Form GNL-1 has to be made before the due date. A company that has not held its FY 2025-26 AGM by now is in default under section 96, which is an offence under section 99. The usual course is to hold the AGM as soon as possible and apply to compound the offence under section 441.

Filing after the new dates costs more than it appears. Paragraph 4 says that a filing made after the circular's dates attracts all fees, including additional fees, counted from the date on which the filing was actually due under the Act, not from 31 December 2026 or 31 January 2027. An AOC-4 originally due on 30 October 2026 and filed in January 2027 would therefore carry additional fees for the whole delay from 30 October.

Not covered by this circular. These stay on their usual due dates unless MCA says otherwise:

• Filings for earlier financial years: the relief applies only to FY 2025-26
• LLP Form 8 (Statement of Account and Solvency), due by 30 October 2026, and LLP Form 11
• MSME Form I for April to September 2026, due by 31 October 2026
• Form ADT-1 for an auditor appointed at the AGM, due within 15 days of the meeting

What to do now:

• If the AGM has been held, file AOC-4 and MGT-7 (or MGT-7A) well before the new dates, so that there is time for any resubmission.
• If the accounts are not yet audited and adopted, plan the audit, the board meeting and the AGM so that AOC-4 can be filed by 31 December 2026.
• If the AGM was not held by 30 September 2026, hold it now and deal with the AGM default separately; the circular does not cure it.
• If you run an LLP, file Form 8 by 30 October 2026 as usual.
• Keep a copy of the circular on the compliance file along with the filing records.

Dates and fees in this note are as on 24 October 2026. Check the MCA website for any later circular before filing.

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