DPT-3 vs Deposit: Which Loans and Receipts Need Reporting?

Not every loan received by a company is a deposit—but that does not automatically mean the company can ignore it for DPT-3 reporting.

This distinction is one of the most important concepts in MCA deposit compliance.

A private limited company may receive money from a director, shareholder, another company, a bank, a customer or another source. The accounting books may simply describe these amounts as “loan,” “advance,” “security deposit” or “unsecured borrowing.”

But for Companies Act compliance, the label used in the ledger is not enough.

The company must examine the source, purpose, terms and statutory classification of the amount.

This becomes particularly important because MCA clarified through the 2019 amendment that Form DPT-3 is used for filing the return of deposits, particulars of transactions not considered deposits under Rule 2(1)(c), or both, for companies other than government companies.

In other words:

DPT-3 reporting is broader than simply reporting traditional deposits.

Understanding this distinction can help companies avoid one of the most common DPT-3 compliance mistakes: assuming that “not a deposit” automatically means “not reportable.”

What Is a Deposit Under Company Law?

The Companies Act, 2013 defines the term deposit and provides the statutory framework governing acceptance and repayment of deposits.

Section 73 generally restricts companies from accepting or renewing deposits from the public except in accordance with the statutory requirements. The Act also contains specific provisions for deposits from members and, for eligible companies, from persons other than members.

However, the definition of deposit is not simply:

“Any money received by a company.”

The Companies (Acceptance of Deposits) Rules, 2014 contain a detailed definition along with exclusions.

Certain categories of money received by a company are specifically excluded from the definition of deposit if the applicable conditions are satisfied.

Therefore, the compliance analysis has two stages:

First: Is the amount a deposit?

Second: If it is not a deposit, does it still fall within the DPT-3 reporting framework?

That second question is where many companies make mistakes.

What Is DPT-3?

DPT-3 is the MCA form connected with the reporting of deposits and specified transactions not considered deposits.

MCA's DPT-3 instruction kit states that the form is used for:

• Return of deposits

• Disclosure of particulars of transactions not considered deposits under Rule 2(1)(c)

• Return of deposits and such non-deposit transactions together

The instruction kit also provides the annual filing timeline of 30 June every year, based on information as at 31 March, for the applicable return.

Therefore, a company should not determine DPT-3 applicability merely by checking whether its books contain an account called “Deposits.”

It should review the broader category of outstanding receipts.

DPT-3 vs Deposit: The Basic Difference

The distinction can be understood simply:

The 2019 amendment is particularly important because it expressly clarified that DPT-3 can cover both deposit transactions and transactions not considered deposits.

Why Does the Difference Matter?

Suppose a private limited company has:

₹50 lakh bank loan

₹20 lakh director loan

₹10 lakh shareholder loan

₹15 lakh customer advance

The company's accounts team may say:

“There are no public deposits, so DPT-3 is not applicable.”

That conclusion may be premature.

Each amount should be examined separately.

The bank loan may fall under a specific exclusion.

The director loan may also be covered by an exclusion subject to prescribed conditions.

The shareholder loan may require a separate analysis.

The customer advance may have its own conditions.

The correct approach is therefore:

Identify → Classify → Verify exclusion → Determine DPT-3 reporting.

Loans From Banks and Financial Institutions

Loans received from banks and certain financial institutions can fall within exclusions from the definition of deposit, subject to the applicable statutory conditions.

For example, a company may have:

• Term loan

• Working-capital facility

• Cash-credit facility

• Equipment finance

• Other institutional borrowing

The company should maintain documents such as:

• Sanction letter

• Loan agreement

• Bank statements

• Repayment schedule

• Interest records

• Security documents, where applicable

The fact that the lender is a bank is relevant to classification, but the company should still retain documentation supporting the nature of the borrowing.

Loans From Directors

Loans received from directors are another frequently misunderstood category.

The deposit rules provide an exclusion for certain amounts received from a director, subject to prescribed conditions.

Therefore, a company cannot simply say:

“Director loan = deposit.”

Nor should it automatically say:

“Director loan = no compliance.”

The company should establish that the transaction satisfies the applicable exclusion.

Supporting documentation can be particularly important.

For example, where the rules require a declaration from the director concerning the source of the funds, the company should maintain that declaration in its records.

Loans From Relatives of Directors

Certain amounts received from relatives of directors have also been addressed within the deposit-rule framework.

However, the exact statutory conditions and applicable company category should be examined before relying on an exclusion.

A company should not assume that every amount received from a director's relative is automatically outside the deposit definition.

The transaction should be documented and assessed under the applicable version of the Rules.

Loans From Members or Shareholders

Amounts received from members/shareholders require careful examination.

The deposit rules contain specific provisions concerning money received from members in certain circumstances.

A company should review:

• Whether the lender is actually a member

• The company's legal status

• The amount received

• Terms of the transaction

• Applicable declarations

• Applicable limits or conditions

• Whether the relevant exclusion applies

• Whether DPT-3 reporting is required

For example, a private company receiving ₹30 lakh from one of its shareholders should not rely solely on the accounting description “shareholder loan.”

The legal relationship and statutory conditions should be verified.

Inter-Corporate Loans

Money received from another company can also fall within specific exclusions under the deposit rules, subject to applicable conditions.

For example:

ABC Private Limited receives ₹1 crore from XYZ Private Limited.

The transaction may be recorded as an inter-corporate loan.

The company should retain:

• Loan agreement

• Board approvals

• Bank transaction records

• Lender details

• Repayment terms

• Interest terms

• Supporting corporate documents

The classification should then be assessed against the applicable exclusion.

Again, the accounting description alone does not determine the legal treatment.

Amounts Received From Alternative Investment Funds and Other Specified Entities

The deposit rules also contain exclusions for certain amounts received from specified regulated investment entities.

The 2019 amendment, for example, refers to amounts received from Alternative Investment Funds, Domestic Venture Capital Funds and Mutual Funds registered with SEBI, subject to the applicable framework.

This can be relevant for companies receiving institutional funding.

For example, a startup may receive funding from an eligible investment fund through an instrument or transaction that initially appears as debt or another form of receipt.

The company should examine the exact instrument and source before classifying it.

Startup Funding and Convertible Notes

Startup funding can require additional attention because certain instruments have specific treatment under the deposit rules.

The rules have addressed convertible notes issued by eligible startup companies under specified conditions. The definition of a convertible note includes an instrument evidencing receipt of money initially as debt that is repayable at the holder's option or convertible into equity shares upon specified events and according to agreed terms.

Therefore, a startup should not assume that every funding instrument described commercially as a “convertible note” receives identical treatment.

The company's eligibility, instrument terms and applicable conditions should be reviewed.

Customer Advances: Are They Deposits?

Customer advances are another area where classification requires care.

Suppose a manufacturing company receives:

₹20 lakh advance from a customer

for an order that will be supplied later.

The company may initially record the amount as a customer advance.

However, the deposit rules contain specific treatment for certain business-related advances, subject to conditions.

The company should therefore examine:

• Nature of the business

• Purpose of the advance

• Agreement/order

• Expected supply date

• Terms of the transaction

• Whether the applicable conditions are satisfied

• Whether the amount remains outstanding beyond any prescribed period

The correct classification cannot be determined from the words “customer advance” alone.

Security Deposits

Security deposits can also require examination.

For example, a company may receive:

• Rental security deposit

• Dealer security deposit

• Distributor security deposit

• Contractual performance deposit

The purpose and terms of the amount matter.

A genuine security deposit connected with a business arrangement may receive different treatment from an amount that is effectively a financing arrangement.

Companies should therefore preserve the underlying agreement and commercial documentation.

Advance for Goods or Services

Amounts received in advance for goods or services can have specific treatment under the deposit rules.

For example, a company manufacturing machinery receives:

₹50 lakh advance from a customer

under a purchase contract.

The company should examine whether the amount satisfies the relevant conditions applicable to business advances.

Important information can include:

• Purchase order

• Contract

• Invoice

• Delivery schedule

• Amount received

• Date received

• Nature of goods/services

• Refund terms

• Whether the transaction was completed within the applicable period

This documentation can help establish the commercial nature of the receipt.

Government Grants and Other Specified Receipts

Certain amounts received by companies can also fall within specific exclusions depending on their nature and source.

The company should therefore review its books for more than just loans.

Potentially relevant categories may include:

• Grants

• Government-related funding

• Securities application money

• Advance against securities

• Business advances

• Security deposits

• Insurance-related receipts

• Certain regulated financial arrangements

Each category has its own conditions.

The company should not combine all such amounts into one generic “other liabilities” category for DPT-3 analysis.

Securities Application Money

Money received against securities can also have specific statutory treatment.

For example, a company receives:

₹1 crore from an investor against proposed share allotment.

The company should examine whether the amount has been properly dealt with under the Companies Act and deposit rules.

The timing of allotment and treatment of any amount that remains outstanding can become relevant.

This is an area where the company should reconcile its:

Bank records → Share application records → Board resolutions → PAS-3 → Financial statements → DPT-3 analysis

where applicable.

When Does a Non-Deposit Amount Become Relevant for DPT-3?

This is the central question.

The 2019 amendment clarified that Form DPT-3 can be used for reporting transactions not considered deposits under Rule 2(1)(c).

Therefore, the fact that a receipt falls within an exclusion from the deposit definition does not automatically remove it from the DPT-3 reporting exercise.

For example:

Director loan → may not be a deposit → may still be reportable in DPT-3

Bank borrowing → may not be a deposit → should still be evaluated for DPT-3

Customer advance → may not be a deposit → should still be evaluated

The precise reporting treatment depends on the applicable rules and the company's facts.

A Practical DPT-3 Classification Table

A company can initially organise its review like this:

This table is a starting point for classification, not a substitute for checking the exact statutory conditions.

Practical Example: A Delhi Private Limited Company

Consider a private limited company in Delhi with the following outstanding amounts as of 31 March:

• ₹40 lakh bank loan

• ₹15 lakh director loan

• ₹10 lakh shareholder loan

• ₹20 lakh customer advance

• ₹5 lakh security deposit

The company should not enter ₹90 lakh into DPT-3 simply because all five amounts appear as liabilities.

It should first analyse each amount.

Bank loan

Review the applicable exclusion and loan documentation.

Director loan

Check the applicable director declaration and conditions.

Shareholder loan

Verify whether the member-related exclusion applies.

Customer advance

Review the underlying customer contract and applicable conditions.

Security deposit

Examine the commercial purpose and relevant documentation.

Only after this classification should the company determine the appropriate DPT-3 reporting.

Example: Startup in Gurugram

Suppose a startup receives:

₹50 lakh from a recognised investment fund

and

₹25 lakh from its founder as a temporary loan.

The startup should not classify both amounts identically.

The source of the investment-fund money and the exact funding instrument should be checked against the relevant exclusion.

The founder loan should separately be assessed under the director/member and other applicable provisions.

This demonstrates why the source and legal character of the receipt matter.

DPT-3 Reporting Date

The annual DPT-3 return is based on information as at 31 March and is generally filed by 30 June of the relevant year for the applicable annual return. MCA's instruction kit specifies this annual timeline.

Therefore, companies should freeze their DPT-3 classification based on the relevant reporting date and reconcile the amounts with their books.

Example

For:

31 March 2026

the annual DPT-3 filing deadline is generally:

30 June 2026

The company should therefore review outstanding receipts as at 31 March before preparing the filing.

Documents to Maintain for DPT-3 Classification

A company should maintain documentary evidence supporting its classification of receipts.

Depending on the transaction, this can include:

• Loan agreements

• Bank sanction letters

• Bank statements

• Director declarations

• Member/shareholder records

• Board resolutions

• Inter-corporate loan agreements

• Customer contracts

• Purchase orders

• Security deposit agreements

• Share application records

• Convertible note agreements

• Investment agreements

• Funding documents

• Repayment schedules

• Interest records

• Financial statements

• Ledger extracts

The purpose is not to upload every document to MCA.

The purpose is to ensure that the company can support why a particular receipt was treated as a deposit or non-deposit.

Common DPT-3 Classification Mistakes

Companies frequently make mistakes such as:

• Assuming every loan is a deposit

• Assuming every loan is exempt

• Assuming director loans never need reporting

• Assuming shareholder loans are automatically exempt

• Treating all customer advances identically

• Ignoring the terms of security deposits

• Ignoring the source of institutional funding

• Using accounting labels as legal classifications

• Failing to maintain director declarations

• Not reconciling DPT-3 with the balance sheet

• Ignoring amounts outstanding as of 31 March

• Assuming “not a deposit” means “not reportable”

• Using outdated DPT-3 guidance

• Missing the 30 June filing deadline

DPT-3 Compliance Checklist

Before finalising DPT-3, companies can follow this checklist:

• Obtain the latest balance sheet

• Extract all relevant outstanding receipts

• Categorise each receipt by source

• Identify the purpose of each transaction

• Review the applicable deposit-rule exclusion

• Check director/member declarations

• Review loan agreements

• Review customer advances

• Review security deposits

• Review securities application money

• Review institutional funding

• Check startup/convertible-note transactions where applicable

• Reconcile balances as at 31 March

• Verify financial-statement figures

• Determine whether each amount is a deposit or specified non-deposit transaction

• Check the appropriate DPT-3 return type

• Prepare applicable attachments

• Check certification requirements

• File by 30 June

• Preserve the filed form and supporting records

DPT-3 Is a Classification Exercise, Not Just a Filing Exercise

This is perhaps the most useful way to understand DPT-3.

A company should not begin with:

“Which number should we enter in DPT-3?”

It should begin with:

“What amounts did we receive, from whom, for what purpose, and how are they treated under the Companies Act and Deposit Rules?”

Once that analysis is completed, the DPT-3 reporting position becomes much clearer.

This approach is especially useful for companies that have multiple types of financing during the year.

Final Takeaway

A deposit and a DPT-3-reportable transaction are not necessarily the same thing.

The Companies (Acceptance of Deposits) Rules contain exclusions from the definition of deposit, while the DPT-3 framework also covers specified transactions that are not considered deposits. MCA expressly clarified this position in the 2019 amendment to Rule 16.

Therefore, companies should review their outstanding receipts category by category.

The key questions are:

Who provided the money?

Why was it received?

What are the terms?

Does a statutory exclusion apply?

Is the amount still required to be reported through DPT-3?

The annual DPT-3 return is generally filed by 30 June, based on information as at 31 March, for the applicable reporting framework.

For companies in Delhi, Noida, Gurugram, Ghaziabad, Faridabad and across India, maintaining proper documentation for loans, advances, investments and other receipts throughout the year can make DPT-3 classification considerably easier.

Need Help With DPT-3 and Deposit Compliance?

If your company needs assistance with DPT-3 filing, deposit classification, loan documentation or broader ROC/MCA compliance, FilingSuvidha can help review the relevant information and organise the filing process.

Website: FilingSuvidha
Phone: +91-9625995981
Email: info@filingsuvidha.com

Our focus is on transparent pricing and on-time delivery.

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 a deposit or falls within an exclusion depends on the specific facts, transaction terms, source of funds and applicable provisions. DPT-3 reporting requirements, MCA forms and regulatory rules may change. Companies should verify the latest applicable requirements before making a filing.