A company may believe that DPT-3 applies only when it accepts deposits—but that is one of the most common misunderstandings surrounding this MCA compliance form.
A company can have outstanding loans, advances or other receipts that are not treated as deposits under the Companies (Acceptance of Deposits) Rules, 2014, and those amounts can still become relevant for DPT-3 reporting.
This is why companies should not ask only, “Have we accepted any deposits?”
The more useful question is:
“Do we have any outstanding amounts that are required to be reported under the DPT-3 framework?”
Form DPT-3 is governed by Rules 3, 16 and 16A of the Companies (Acceptance of Deposits) Rules, 2014. The MCA's DPT-3 instruction kit states that a company other than a government company is required to file the return in respect of deposits accepted, and the form also covers the reporting framework for specified outstanding receipts that are not considered deposits.
For companies in Delhi, Noida, Gurugram and across India, DPT-3 should therefore be treated as an annual ROC/MCA compliance review rather than a form that is relevant only when the company raises money from the public.
What Is DPT-3 Filing?
DPT-3 is an MCA form relating to deposits and certain outstanding amounts received by a company that fall within the reporting framework under the Companies (Acceptance of Deposits) Rules, 2014.
The form is titled “Return of Deposits”, but its practical reporting scope can extend beyond amounts that are legally classified as deposits.
The MCA instruction kit explains that a company other than a government company is required to file the return in respect of deposits accepted by the company, with the Registrar by 30 June every year, furnishing information as on 31 March of that year.
This distinction matters because an amount can be:
A deposit, or
An amount that is not a deposit but is nevertheless required to be reported under the DPT-3 framework.
Therefore, companies should review their outstanding financial liabilities before concluding that DPT-3 is irrelevant.
Why Is DPT-3 Important?
The Companies Act regulates the acceptance of deposits by companies.
Section 73 generally prohibits companies from inviting, accepting or renewing deposits from the public except in accordance with the statutory framework. The Act also provides specific provisions for accepting deposits from members and, subject to prescribed conditions, deposits from the public by certain companies.
DPT-3 forms part of the reporting framework connected with these deposit provisions.
For a company, the compliance exercise is therefore not simply about identifying the word “deposit” in its accounting records.
It requires an assessment of the nature and source of outstanding amounts.
Who Needs to File DPT-3?
The MCA instruction kit states that a company other than a government company is required to file DPT-3 in respect of deposits accepted by the company.
In addition, the DPT-3 framework covers specified outstanding receipts that are not considered deposits under the relevant exemption provisions.
Therefore, companies should review their balance sheet and supporting records to determine whether reportable amounts exist.
This can be particularly important for companies that have:
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Loans from directors
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Loans from shareholders
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Inter-corporate loans
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Bank borrowings
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Unsecured loans
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Security deposits
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Advances
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Certain customer-related receipts
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Other outstanding receipts covered by the applicable rules
The fact that an amount is called a “loan” in the books does not by itself answer whether DPT-3 reporting applies.
Does Every Company With a Loan Need to File DPT-3?
Not necessarily.
This is one of the most important points to understand.
A company having a loan does not automatically mean that the amount is a “deposit” under the Companies Act.
The Companies (Acceptance of Deposits) Rules contain exclusions for specified categories of receipts and amounts.
Therefore, the company needs to determine:
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What is the source of the money?
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Why was the money received?
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When was it received?
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What are the terms of repayment?
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Who provided the money?
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Does the amount fall within one of the exclusions from the definition of deposit?
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Does the amount nevertheless fall within the DPT-3 reporting framework?
This distinction becomes especially important for privately held companies receiving unsecured loans from promoters, directors or related parties.
Deposit vs Exempted Amount
The word “deposit” has a specific statutory meaning.
The Companies (Acceptance of Deposits) Rules also identify certain amounts that are not treated as deposits for the purposes of the rules.
Therefore, a company can have an amount that is:
Not a deposit under the Rules
but may still need to be considered for DPT-3 reporting.
This is why the terms “deposit” and “DPT-3 reportable amount” should not automatically be treated as synonyms.
The next article in this series will specifically explain DPT-3 vs Deposit and examine which loans and receipts may need reporting.
Common Amounts That Companies Should Review
A company preparing for DPT-3 should review its balance sheet and underlying ledgers for relevant liabilities.
Important categories can include:
Loans from directors
Amounts received from directors can have specific treatment under the deposit rules, subject to the conditions prescribed by the applicable rules.
Companies should maintain appropriate declarations and supporting documentation where the relevant exemption is being relied upon.
Loans from shareholders
Loans received from members/shareholders require careful classification.
The source of the funds, nature of the shareholder relationship and applicable conditions should be examined rather than assuming that every shareholder loan is automatically outside the deposit framework.
Bank and financial institution borrowings
Loans from banks and specified financial institutions can fall within prescribed exclusions, subject to the applicable conditions.
The company should retain the relevant sanction letters, loan agreements and financial records supporting the classification.
Inter-corporate loans
Amounts received from another company may also need to be reviewed against the applicable exclusions.
The name of the lender alone is not enough; the company should verify the exact statutory category and supporting documents.
Customer advances
Customer advances can require careful examination.
An advance received for goods or services is not necessarily treated the same way as a financial borrowing. The applicable rules contain specific treatment for certain business-related advances and their conditions.
Companies should therefore examine the commercial substance and terms of the receipt.
Security deposits
Security deposits received in connection with business arrangements should also be reviewed against the applicable rules.
The purpose and terms of the security deposit can affect its classification.
What Is the DPT-3 Due Date?
The MCA's current DPT-3 instruction kit states that a company other than a government company must file the return with the Registrar on or before 30 June every year, furnishing information as at 31 March of that year.
For example, for information as at:
31 March 2026
the ordinary DPT-3 filing deadline is:
30 June 2026
This makes DPT-3 a recurring annual compliance requirement for companies to which the reporting provisions apply.
Companies should therefore begin reviewing their loan and liability records before the June deadline instead of waiting until the final days.
What Information Is Required in DPT-3?
DPT-3 requires the company to provide information concerning its corporate identity, financial position and the amounts being reported.
The prescribed form includes fields relating to areas such as:
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Corporate Identity Number
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Company name
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Registered office
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Email address
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Company type
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Government-company status
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Objects of the company
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Relevant financial information
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Net worth
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Amounts outstanding
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Nature of receipts
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Details of deposits, where applicable
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Particulars of depositors, where applicable
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Other prescribed information
The precise fields depend on the type of DPT-3 return being filed and the current MCA form.
Company Details Required
The company should keep its basic MCA information ready.
This generally includes:
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CIN
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Legal name
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Registered office address
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Email ID
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Company type
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Relevant financial-year information
The details should match the company's current MCA records.
If the company recently changed its registered office or legal name, those changes should be reconciled before DPT-3 is prepared.
Financial Information Required
DPT-3 can require financial information relating to the company's net worth and outstanding amounts.
The prescribed form has historically required details such as:
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Paid-up share capital
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Free reserves
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Securities premium
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Accumulated losses
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Other relevant financial information
The MCA's prescribed DPT-3 format specifically contains a section for net-worth information.
Therefore, the company should coordinate DPT-3 preparation with its accounts team rather than preparing the form solely from a loan ledger.
Information About Outstanding Amounts
The company should identify the relevant outstanding amounts as of the reporting date.
For each category, the company may need to establish:
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Amount outstanding
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Nature of receipt
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Source of funds
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Date of receipt
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Terms of repayment
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Interest, where applicable
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Whether secured or unsecured
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Relevant exemption/category
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Supporting documents
This classification exercise is often the most important part of DPT-3 preparation.
Deposit Details, Where Applicable
If the company has actually accepted deposits under the applicable provisions, the return can require information relating to those deposits.
This can include:
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Number of depositors
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Amount of deposits
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Amount outstanding
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Deposits matured but unpaid, where applicable
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Interest payable
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Other prescribed particulars
The company should ensure that the figures reported in DPT-3 reconcile with its books of account.
List of Depositors
The MCA DPT-3 instruction kit specifically states that amounts entered in the webform should match the amounts provided in the “List of depositors” attachment, where that attachment is applicable.
This is an important reconciliation point.
If the DPT-3 form reports one amount while the supporting depositor list contains a different amount, the company can face filing issues.
The figures should therefore be checked before submission.
Auditor Certification and DPT-3
DPT-3 has specific certification/documentation requirements depending on the nature of the return.
The MCA's prescribed DPT-3 framework and form documentation should be reviewed to determine whether an auditor's certificate is required for the particular filing.
Companies should not assume that every DPT-3 filing requires the same supporting certification.
The requirement can depend on the type of return and the amounts being reported.
This is one reason why companies should identify the applicable DPT-3 category before collecting documents.
Documents to Keep Ready for DPT-3
A practical DPT-3 working file can include:
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Certificate of Incorporation
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Current MCA master data
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Audited financial statements
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Balance Sheet
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Trial balance
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Loan ledger
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Bank statements
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Loan agreements
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Sanction letters
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Director loan declarations, where applicable
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Shareholder/member loan records
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Inter-corporate loan documentation
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Customer advance details
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Security deposit agreements
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Deposit agreements, where applicable
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List of depositors, where applicable
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Auditor certificate, where applicable
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Board resolutions
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Supporting correspondence
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Previous year's DPT-3 filing
Not every document becomes an attachment to the final form.
These records help the company establish why a particular amount has been classified in a particular way.
DPT-3 Filing Process
The practical filing process can be organised into several stages.
Step 1: Review the company's liabilities
Start with the balance sheet and identify all loans, advances, deposits and other potentially relevant receipts.
Step 2: Trace each amount to its source
For each amount, identify:
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Who provided the money?
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Why was it received?
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When was it received?
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What document supports the receipt?
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What are the repayment terms?
Step 3: Determine the legal classification
Review whether each amount is:
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A deposit
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An exempted amount
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Another amount reportable under the DPT-3 framework
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An amount outside the applicable reporting requirement
Step 4: Reconcile the figures
The amounts should agree with:
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Books of account
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Balance Sheet
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Loan schedules
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Bank statements
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Supporting agreements
Step 5: Prepare supporting documents
Collect the applicable declarations, certificates, lists and other supporting documents.
Step 6: Complete DPT-3
Enter the company and financial information in the MCA webform.
Step 7: Digital signing and certification
Complete the applicable digital-signature and professional-certification requirements.
Step 8: Submit and pay applicable fees
Submit the form through the MCA system and pay the applicable filing fee.
Step 9: Preserve the filing record
Download and preserve the filed form, SRN, acknowledgement and supporting documents.
A Practical Example: Director's Loan
Consider a private limited company in Delhi.
During FY 2025–26, one of its directors provides the company with an unsecured loan of ₹20 lakh.
The company records it under “Unsecured Loans – Director.”
At first glance, management may say:
“It is a director's loan, so it is not a deposit.”
That conclusion should not be made solely from the ledger description.
The company should verify the applicable exclusion and conditions under the Companies (Acceptance of Deposits) Rules and maintain the relevant declaration/documentation supporting the classification.
It should then determine whether the amount needs to be reported through DPT-3.
The same principle applies to shareholder loans and other receipts.
Another Example: Bank Borrowing
Suppose a company in Noida has a â‚ą1 crore working-capital facility from a bank.
The company has:
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Loan sanction letter
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Loan agreement
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Bank statements
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Repayment schedule
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Interest records
The company should examine the applicable statutory treatment of the borrowing and maintain the supporting documentation.
The fact that it is a bank loan does not mean the company should simply skip the DPT-3 review. The company should first determine whether the amount falls within the applicable reporting framework.
Example: Customer Advance
Suppose a manufacturing company receives â‚ą25 lakh from a customer as an advance against an order.
The company should examine:
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Purchase/order agreement
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Invoice or advance documentation
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Purpose of payment
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Delivery obligations
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Repayment terms
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Whether the conditions of the relevant exclusion are satisfied
It should not classify the amount solely because the accounting ledger says “Customer Advance.”
The legal classification should be supported by the actual transaction and applicable rules.
DPT-3 and Loans From Directors
Director loans are one of the areas where companies frequently make assumptions.
The deposit rules provide an exclusion for certain amounts received from a director, subject to prescribed conditions.
The company should therefore ensure that the required declaration and supporting evidence are maintained.
For example, where a director provides money from personal funds, the company should maintain the documentation required to establish the source and statutory treatment of the amount.
A simple journal entry is not necessarily sufficient compliance documentation.
DPT-3 and Shareholder Loans
Loans from shareholders also require careful review.
The treatment can depend on whether the person is a member, the nature of the company, the terms of the transaction and the specific conditions prescribed under the Rules.
A company should therefore avoid using a blanket internal policy such as:
“All shareholder loans are exempt from deposits.”
The classification should be checked against the current statutory framework.
DPT-3 for Private Limited Companies
DPT-3 can be particularly relevant for private limited companies because such businesses commonly receive funds through:
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Promoter loans
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Director loans
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Shareholder loans
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Inter-corporate funding
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Unsecured borrowings
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Security deposits
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Customer advances
A company may therefore have no traditional public deposit scheme but still need to evaluate DPT-3 reporting.
This is why annual ROC compliance should include a review of the company's balance-sheet liabilities.
DPT-3 for Startups
Startups often receive money from founders, directors, shareholders, group entities and other sources during their early stages.
For example, a startup in Gurugram may initially receive:
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â‚ą10 lakh from a founder
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â‚ą15 lakh from another director
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â‚ą25 lakh from a group company
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â‚ą50 lakh from an institutional investor
Each transaction can have a different legal and accounting character.
The startup should therefore maintain proper documentation from the date the funds are received rather than trying to reconstruct the transaction history at the time of DPT-3 filing.
Common DPT-3 Mistakes
Some of the most common DPT-3 compliance mistakes include:
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Assuming DPT-3 applies only to public deposits
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Assuming no deposit means no DPT-3 review is required
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Treating every loan as automatically exempt
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Treating every director loan as automatically exempt
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Ignoring shareholder loans
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Ignoring inter-corporate loans
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Not reviewing customer advances
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Incorrect classification of security deposits
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Using balance-sheet figures without tracing the underlying transactions
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Mismatch between DPT-3 and financial statements
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Incorrect net-worth figures
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Missing supporting documents
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Missing depositor list where applicable
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Not checking auditor certification requirements
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Filing after 30 June
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Using outdated rules or old DPT-3 guidance
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Failing to retain supporting documentation
DPT-3 Reconciliation Checklist
Before filing DPT-3, companies can use the following checklist:
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Confirm whether the company is required to file
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Review the latest balance sheet
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Extract all loans and potentially reportable receipts
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Identify the source of each amount
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Review the nature and purpose of each receipt
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Check applicable exclusions from deposits
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Verify director/member declarations
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Review inter-corporate loans
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Review bank and financial institution borrowings
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Review customer advances
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Review security deposits
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Check actual deposits, if any
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Reconcile amounts with the general ledger
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Reconcile amounts with bank statements
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Check the 31 March closing balance
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Prepare applicable supporting documents
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Check list of depositors where applicable
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Check auditor certificate requirement
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Complete the MCA webform
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Verify all figures before signing
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File by 30 June
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Save SRN and final records
What Happens If DPT-3 Is Not Filed?
Failure to comply with the applicable deposit-reporting requirements can expose the company and responsible officers to statutory consequences.
The consequences depend on the nature of the default and the applicable provisions.
It is therefore better to identify the filing obligation before the due date rather than assuming that a company with no traditional deposits is automatically outside the DPT-3 framework.
If a company discovers after the deadline that a DPT-3 filing was required, it should assess the applicable additional filing fee and statutory consequences and take corrective action promptly.
DPT-3 Is Not the Same as Deposit Acceptance
This distinction deserves special attention.
A company can have:
No deposits accepted from the public
but still have:
Outstanding amounts that need to be reported under the DPT-3 framework.
Conversely, the fact that a company has an outstanding loan does not automatically mean:
That loan is a deposit.
These are two different questions.
The correct compliance analysis is:
Identify the amount → Determine its statutory classification → Check whether DPT-3 reporting applies → Prepare the applicable return.
Final Takeaway
DPT-3 filing is an annual MCA compliance requirement that companies should assess based on the nature of their outstanding receipts, not merely on whether they call something a “deposit” in their accounting records.
The MCA's DPT-3 instruction kit states that, for companies other than government companies, the return is filed on or before 30 June each year, with information as at 31 March.
The most important part of DPT-3 compliance is classification.
A company should review:
Bank loans → Director loans → Member/shareholder loans → Inter-corporate loans → Customer advances → Security deposits → Actual deposits → Other relevant receipts
Each amount should then be assessed against the Companies Act and the Companies (Acceptance of Deposits) Rules.
For businesses in Delhi, Noida, Gurugram, Ghaziabad, Faridabad and across India, maintaining proper loan agreements, declarations, bank records and accounting documentation throughout the year can make DPT-3 preparation much easier.
Need Help With DPT-3 Filing and MCA Compliance?
If your company needs assistance with DPT-3 filing, deposit classification, loan documentation or complete ROC/MCA compliance, FilingSuvidha can help organise the applicable information and filing process.
Website: FilingSuvidha
Phone: +91-9625995981
Email: info@filingsuvidha.com
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Disclaimer
This article is intended for general informational purposes and should not be treated as legal, accounting, company-secretarial or professional advice. Whether a particular loan, advance, deposit or receipt is reportable under DPT-3 depends on the specific facts, source of funds, transaction terms and applicable provisions of the Companies Act and Companies (Acceptance of Deposits) Rules. MCA forms, rules, filing procedures and regulatory requirements may change. Companies should verify the latest applicable requirements before filing.