E35

Engagement

Deactivated DIN and disqualified directors

Last reviewed 07 November 2026

Reactivating a DIN and dealing with director disqualification.

In short

A DIN is marked deactivated when the director misses DIR-3 KYC; filing the KYC with the late fee of ₹5,000 reactivates it. Disqualification is different: a director of a company that has not filed its financial statements or annual returns for three continuous financial years is disqualified for five years under section 164(2), and vacates office in other companies.

Overview

Deactivated DIN: every director files DIR-3 KYC on the cycle set by the rules. A director who misses it has the DIN marked 'Deactivated due to non-filing of DIR-3 KYC', and cannot sign or be named in MCA filings until the KYC is filed with the late fee. See [DIR-3 KYC on the three-year cycle](/insights/dir-3-kyc-three-year-cycle).

Disqualified director: where a company has not filed its financial statements or annual returns for any continuous period of three financial years, each of its directors is disqualified under section 164(2) from being appointed or reappointed in any company for five years, and vacates office in the other companies where he or she is a director (section 167).

The practice reads the director's and the companies' MCA records, files the pending KYC and returns in the right order, appoints replacement directors where a company would otherwise be left without its minimum, and advises on the route to have a disqualification addressed in the director's facts.

Key Deliverables

  • Review of the DIN status and every company where the person is a director
  • DIR-3 KYC filing to reactivate a deactivated DIN
  • Catch-up filings for the company whose default caused the disqualification
  • Appointment of replacement directors and DIR-12
  • Advice on the options for lifting a disqualification

Documents & E-Forms

  • DIR-3 KYC
  • DIR-12
  • AOC-4
  • MGT-7

When to Engage

As soon as a DIN shows 'Deactivated' or 'Disqualified' on the MCA portal, or a filing is rejected because of a director's DIN status.

Typical turnaround: Scoped in the engagement letter.

Frequently Asked

About this engagement

By filing DIR-3 KYC with the late fee of ₹5,000.

When a company of which he or she is a director has not filed its financial statements or annual returns for any continuous period of three financial years.

Five years from the date the company failed to file.

No. Deactivation is for a missed KYC and is fixed by filing it. Disqualification follows the company's default in filing returns.
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