Missing one ROC deadline can turn a routine annual compliance task into a costly exercise—especially when several MCA filings fall close together after the financial year ends.

A private limited company's compliance does not happen only once a year.

Throughout the year, companies may have to manage:

• Board meetings

• General meetings

• Statutory audit

• AOC-4 filing

• MGT-7 or MGT-7A

• ADT-1

• DIR-3 KYC

• DPT-3

• MSME Form-1, where applicable

• Event-based MCA filings

• Charge-related filings

• Director-related filings

• Share-capital filings

The exact compliance requirements depend on the company's size, structure, transactions, financial year, directors, borrowing arrangements and other circumstances.

For a private limited company in Delhi, Noida, Gurugram, Ghaziabad, Faridabad or elsewhere in India, maintaining a month-wise ROC compliance calendar can help management coordinate its accounts, company secretary, auditor and finance teams.

MCA itself identifies forms such as AOC-4, MGT-7/MGT-7A, ADT-1, DIR-12, DPT-3, MGT-14, CHG-1, INC-22 and SH-7 among the company's filing framework.

What Is ROC Annual Compliance?

ROC annual compliance refers to the recurring statutory filings and corporate procedures that companies are required to complete with the Registrar of Companies and under the Companies Act, 2013.

For a typical private limited company, the annual cycle broadly involves:

Financial year closure → accounts finalisation → audit → Board approval → AGM → AOC-4 → annual return → other recurring compliances

However, not every filing is annual.

Some compliances are:

• Half-yearly

• Event-based

• Transaction-based

• Director-specific

• Charge-specific

• Capital-specific

A good compliance calendar therefore needs to combine annual, periodic and event-based requirements.

A Typical ROC Compliance Calendar

A simplified calendar for a financial year can look like this:

This is only a planning framework.

The actual due date must be calculated based on the company's financial year, AGM date, transaction date and specific statutory requirement.

Why a Month-Wise Calendar Matters

A company can have excellent accounting records and still face compliance issues if filings are not tracked properly.

For example, after the financial year ends on 31 March, several activities may overlap:

• Books need to be closed

• Audit needs to be completed

• Financial statements need approval

• AGM needs to be conducted

• AOC-4 needs to be filed

• MGT-7/MGT-7A needs to be filed

• Auditor appointment/reappointment compliance may need attention

At the same time, DPT-3 may have its own deadline, and MSME Form-1 may also become relevant.

A month-wise calendar helps separate these obligations.

April: Start the New Compliance Cycle

April is the beginning of the new financial year for companies following the April–March financial year.

It is also an important month because the previous financial year's accounts have just closed.

1. Close the Previous Financial Year

The finance team should begin finalising:

• Sales records

• Purchase records

• Bank reconciliation

• Debtors

• Creditors

• Fixed assets

• Loans

• Employee-related liabilities

• GST balances

• TDS balances

• Outstanding expenses

• Advances

• Share capital

The objective is to prepare reliable financial statements.

2. Review MSME Payments

For the period ending 31 March, companies should review their payments to micro and small enterprise suppliers.

Where the applicable MSME Form-1 conditions are met, the filing deadline for the October–March period is 30 April.

The company should therefore identify relevant MSE suppliers well before the deadline.

The review should include:

• Supplier status

• PAN

• Acceptance/deemed acceptance date

• Invoice amount

• Payment date

• Outstanding amount

• Ageing

• Reason for delay

3. Review Outstanding Charges

April is also a useful time to review the company's loan and charge register.

Check:

• Active bank loans

• New charges

• Modified charges

• Repaid loans

• Charges still appearing as outstanding on MCA

• CHG-4 requirements for satisfied charges

A company that repaid a secured loan during the previous year should verify whether the applicable satisfaction filing has been completed.

May: Accounts and Audit Preparation

May is generally an important preparation month.

The company should work with its auditor to finalise the annual financial statements.

Key Records to Reconcile

The company should review:

• Bank accounts

• Loans

• Trade receivables

• Trade payables

• Fixed assets

• Inventory

• Statutory dues

• Related-party transactions

• Share capital

• Reserves

• Director-related balances

• Outstanding expenses

The accounts should also be reconciled with the company's MCA records wherever relevant.

Check Director and Shareholding Changes

Before annual filings are prepared, the company should review whether any events occurred during the year involving:

• Appointment of director

• Resignation of director

• Removal of director

• Change in designation

• Allotment of shares

• Transfer of shares

• Increase in authorised capital

• Creation or satisfaction of charge

Event-based filings should not be forgotten simply because the company is preparing its annual return.

June: DPT-3 and Loan Review

One of the important ROC compliance deadlines in June is DPT-3, where applicable.

DPT-3

DPT-3 is connected with reporting deposits and specified outstanding receipts under the Companies (Acceptance of Deposits) Rules.

The annual return is generally filed by 30 June, based on information as at 31 March.

Companies should review:

• Bank loans

• Director loans

• Shareholder/member loans

• Inter-corporate loans

• Customer advances

• Security deposits

• Other relevant receipts

The company should classify these amounts carefully before filing.

Reconcile DPT-3 With Financial Statements

A useful June exercise is:

Balance Sheet → loan schedule → bank statements → DPT-3 working → final filing

If the numbers do not reconcile, the company should investigate before filing.

For example:

Balance Sheet shows:

₹1.25 crore borrowings

DPT-3 working shows:

₹1.10 crore

The ₹15 lakh difference should be explained.

It may relate to:

• Timing

• Classification

• Repayment

• Interest

• A new borrowing

• Incorrect accounting

July: Prepare for AGM

July is often a useful month to begin preparing for the AGM.

The company should start coordinating:

• Financial statements

• Auditor's report

• Board's report

• Notice of AGM

• Directors' disclosures

• Statutory registers

• Shareholder records

• AGM agenda

• Minutes documentation

The exact AGM date should be planned according to the Companies Act and the company's circumstances.

AGM Timeline

For most companies, the AGM must generally be held within six months from the close of the financial year, except that the first AGM is subject to the specific first-AGM timeline under Section 96.

For a financial year ending:

31 March

the ordinary six-month window generally runs up to:

30 September

The company should not automatically select 30 September without checking the statutory requirements and its previous AGM history.

August: Audit, Board Approval and AGM Preparation

By August, many companies should be approaching the final stages of their annual closing process.

Board Approval of Financial Statements

The financial statements need to go through the appropriate Board approval process before being placed before members at the AGM.

The company should ensure that:

• Financial statements are final

• Board report is ready

• Auditor's report is available

• Directors' disclosures are complete

• AGM notice is prepared

Auditor Appointment/Reappointment

Where the statutory auditor is being appointed or reappointed at the AGM, the company should also review its ADT-1 compliance.

The appointment of an auditor and the filing of information with the Registrar are separate from AOC-4 and MGT-7.

The company should therefore include auditor compliance in its annual calendar.

September: AGM and Annual Compliance

September is often one of the busiest months for private limited companies because many companies schedule their AGM during this period.

Conduct the AGM

The AGM should be conducted according to:

• Companies Act requirements

• Articles of Association

• AGM notice

• Applicable secretarial procedures

• Voting requirements

The company should maintain:

• Notice

• Attendance records

• Minutes

• Resolutions

• Voting records where applicable

Finalise Annual Filing Deadlines

Two important annual filings are:

AOC-4

and

MGT-7/MGT-7A, depending on the company's eligibility.

Their deadlines are calculated from the AGM rather than simply using a universal calendar date.

AOC-4: Financial Statement Filing

Section 137 requires the company to file its financial statements and applicable documents with the Registrar.

For an ordinary company, AOC-4 is generally filed within 30 days of the AGM.

For example:

AGM: 20 September

The AOC-4 deadline is generally calculated from that AGM date.

This is why saying:

"AOC-4 is always due on 30 October"

is not technically correct.

The actual deadline depends on the AGM date.

What Is Filed With AOC-4?

Depending on the company and financial statements, the filing package can include:

• Balance Sheet

• Statement of Profit and Loss

• Cash Flow Statement, where applicable

• Notes to accounts

• Auditor's report

• Board's report

• Other prescribed documents

The applicable form can differ depending on the company's reporting requirements.

MCA separately recognises AOC-4, AOC-4 CFS and AOC-4 XBRL for applicable companies.

MGT-7 or MGT-7A

The annual return is another major annual ROC compliance.

Since the 2021 amendment, OPCs and small companies file MGT-7A, while other companies generally file MGT-7.

The annual return contains information concerning areas such as:

• Registered office

• Principal business activities

• Share capital

• Shareholding

• Members

• Promoters

• Directors

• KMP

• Meetings

• Remuneration

• Indebtedness

• Penalties and other prescribed information

MGT-7 Deadline

The annual return is generally filed within 60 days from the date of the AGM.

For example:

AGM: 20 September

The company should calculate the 60-day period from that date.

Again, the annual return deadline is therefore not a fixed calendar date for every company.

October: AOC-4 and MGT-7 Filing Season

October is often an important annual filing month.

Suppose a company held its AGM on:

30 September

Its annual filing deadlines will fall after the AGM based on the statutory periods.

The company should prepare:

• AOC-4

• MGT-7/MGT-7A

• Auditor-related filing

• Other applicable annual forms

MSME Form-1 for April–September

October is also relevant for MSME Form-1.

For the April–September reporting period, the applicable filing deadline is:

31 October

where the company's circumstances fall within the amended MSME Form-1 applicability framework.

The company should therefore review its MSE supplier payments during October.

November: MSME Form-1 and Annual Filing Follow-Up

By November, companies should review whether all annual filings due after the AGM have actually been completed.

The compliance team should verify:

• AOC-4 approval

• MGT-7/MGT-7A approval

• ADT-1, where applicable

• MSME Form-1, where applicable

• Filing acknowledgements

• Additional fee, if any

• MCA master-data updates

Reconcile Annual Filings With Accounts

A useful post-filing review is:

Financial statements ↔ AOC-4 ↔ Annual return ↔ Share capital records

For example:

If AOC-4 shows:

Paid-up capital: ₹25 lakh

but the annual return shows:

Paid-up capital: ₹30 lakh

the company should investigate the difference.

December: Review Event-Based Compliance

December is a useful time to perform a broader compliance health check.

Review whether any events during the year required forms such as:

• DIR-12

• MGT-14

• PAS-3

• SH-7

• CHG-1

• CHG-4

• INC-22

• Other applicable MCA forms

These are not necessarily annual forms.

They arise because of specific corporate events.

Example: Director Resignation

Suppose a director resigned on:

15 November

The company should not wait until the next annual return.

DIR-12 has its own event-based filing requirement.

The same principle applies to appointments, designation changes and other reportable events.

January: Mid-Year Compliance Review

January is a good time for management to conduct a mid-year compliance review.

The company can examine:

• Directors

• Shareholders

• Share capital

• Charges

• Loans

• Registered office

• Statutory registers

• MCA master data

• Annual filing status

• Event-based filings

• MSME supplier payments

This can identify issues before the financial year closes.

Review the Registered Office

Check whether the MCA registered-office address is still accurate.

If the company moved during the year, verify whether the appropriate filing was completed.

An outdated registered office can create problems with:

• MCA notices

• Legal correspondence

• Bank KYC

• GST records

• Regulatory communication

February: Prepare for Financial Year-End

February can be used to prepare for the upcoming 31 March closing.

The finance and compliance teams can begin reviewing:

• Outstanding loans

• Director balances

• Share capital

• Debtors

• Creditors

• MSE supplier balances

• Fixed assets

• Charges

• Related-party transactions

This gives the company a head start before the books close.

March: Year-End Compliance Review

March is the final month of the financial year.

The company should prepare a closing checklist covering:

• Share capital

• Loans

• Charges

• Directors

• Shareholders

• MSE suppliers

• Outstanding statutory dues

• Related-party balances

• Corporate actions

• Registered office

• Pending MCA forms

Review Charges Before Year-End

If a company has recently:

• Taken a secured loan

• Modified a facility

• Repaid a loan

• Released security

the finance and compliance teams should check whether:

• CHG-1

• CHG-4

• Other charge-related filings

are required.

Review Share Capital

If the company issued shares during the year, verify:

• Board approval

• Shareholder approval where applicable

• MGT-14 where applicable

• PAS-3

• SH-7, if authorised capital changed

• Share certificates

• Register of members

• Depository records

This is particularly useful before annual return preparation.

Recurring Director Compliance: DIR-3 KYC

Not every ROC compliance item fits neatly into the company's financial-year calendar.

DIR-3 KYC is a director-related annual compliance.

The company should track the applicable annual deadline for every individual who is required to complete DIR-3 KYC or the applicable KYC web process.

MCA has specifically issued updates concerning DIR-3 KYC and related portal processes.

The company should maintain a director-wise tracker containing:

• DIN

• Director name

• KYC status

• Email

• Mobile

• DSC status

• Filing date

• SRN/acknowledgement where applicable

Why Director KYC Should Be Tracked Separately

A company may complete all its annual company filings and still have an individual director compliance issue.

Therefore, the compliance calendar should have a separate section for:

Company-level compliance

and

Director-level compliance

Event-Based Compliance: Don't Wait for the Annual Calendar

A major mistake is putting every ROC form into one annual checklist.

Some filings become due immediately after an event.

Director Appointment or Resignation

DIR-12 is generally required within the prescribed period after:

• Appointment

• Resignation

• Cessation

• Change in designation

The company should therefore maintain an event register.

Share Allotment

After an applicable allotment, PAS-3 needs to be considered within the statutory timeline.

The company should not wait for AOC-4 or MGT-7.

Change in Authorised Capital

If authorised share capital is altered, SH-7 needs to be considered.

Registered Office Change

If the registered office changes, INC-22 needs to be considered within the applicable statutory period.

Creation of Charge

If a registrable charge is created or modified, CHG-1 may become applicable.

Satisfaction of Charge

When a registered charge is fully satisfied, CHG-4 should be reviewed.

Annual Compliance vs Event-Based Compliance

The distinction can be summarised as follows:

MCA's own published filing data identifies many of these forms within the company's compliance framework.

A Private Limited Company's Annual Compliance Master Checklist

A company can maintain one master checklist covering:

Corporate Records

• Board meetings

• General meetings

• Minutes

• Statutory registers

• Director records

• Shareholder records

Financial Compliance

• Financial statements

• Audit

• Board approval

• AGM

• AOC-4

• MGT-7/MGT-7A

Director Compliance

• DIR-3 KYC

• DIR-12 for applicable events

Borrowing and Deposit Compliance

• DPT-3

• CHG-1

• CHG-4

• Loan reconciliation

Share Capital Compliance

• SH-7

• PAS-3

• MGT-14 where applicable

• Shareholder register

• Capital reconciliation

MSME Compliance

• Supplier classification

• Outstanding payment review

• MSME Form-1 where applicable

Registered Office

• MCA address

• INC-22 where applicable

• GST address

• Bank address

• Other registrations

Practical Example: Delhi Private Limited Company

Consider a Delhi private limited company with:

• 15 employees

• ₹3 crore annual turnover

• Two directors

• Five shareholders

• One bank loan

• Ten MSE suppliers

Its compliance calendar may include:

April

Review MSE payments and prepare MSME Form-1 where applicable.

June

Prepare DPT-3 working.

July–September

Finalise accounts and conduct AGM.

After AGM

File AOC-4 and MGT-7/MGT-7A within their respective statutory periods.

September

Track director KYC requirements.

October

Review MSME Form-1 for April–September.

Throughout the year

Track DIR-12, PAS-3, SH-7, CHG-1, CHG-4 and INC-22 whenever the relevant event occurs.

This is much safer than keeping a single reminder saying:

"Do ROC compliance once a year."

Practical Example: Noida Startup

A Noida startup raises funding during the year.

Its compliance calendar changes because of the transaction.

The company may need to consider:

• Authorised capital increase

• MGT-14

• SH-7

• Share issue documentation

• PAS-3

• Share register update

• Annual return update

The funding transaction therefore creates additional compliance outside the normal annual calendar.

Practical Example: Gurugram Company Takes a Loan

A Gurugram company obtains a secured loan during the year.

The company should add:

Charge creation → CHG-1

to its event-based compliance tracker.

When the loan is eventually repaid:

Charge satisfaction → CHG-4

should be considered.

The annual compliance calendar should therefore be supplemented by a live financing tracker.

How to Maintain a ROC Compliance Tracker?

A practical compliance tracker can include:

The most important column is often Trigger Date.

A company should not manage event-based filings using fixed calendar dates.

Keep a Separate Event Register

The company should maintain an event register containing:

• Date of event

• Nature of event

• Relevant section

• Applicable form

• Due date

• Person responsible

• Supporting documents

• Filing status

• SRN

• Approval date

Examples of events include:

• Director appointment

• Director resignation

• Share allotment

• Share transfer

• Loan creation

• Loan repayment

• Charge modification

• Registered-office change

• Capital increase

• Special resolution

This register can be more useful than a simple annual calendar.

Common ROC Compliance Mistakes

Treating Every Deadline as a Fixed Date

Many MCA deadlines depend on an event.

AOC-4 and MGT-7, for example, are linked to the AGM.

Therefore, companies should calculate the deadline from the actual event date.

Preparing Annual Filings Without Reconciling Records

Before filing annual returns, the company should reconcile:

• Share capital

• Directors

• Shareholders

• Charges

• Financial statements

• Corporate events

Otherwise, one MCA form may contain information inconsistent with another.

Ignoring Small Corporate Events

A director may resign in February.

A company may issue shares in May.

A loan may be repaid in August.

A registered office may change in December.

These events can create separate filing requirements.

They should not be postponed until the next annual filing.

Not Maintaining Supporting Documents

A company should preserve:

• Filed forms

• Challans

• SRNs

• Approvals

• Board minutes

• Shareholder resolutions

• Financial statements

• Supporting documents

This creates a defensible compliance trail.

A Better ROC Compliance Strategy

Instead of treating ROC compliance as a year-end exercise, companies can divide responsibilities into four layers.

Layer 1: Monthly Review

Check for:

• Directors

• Share capital changes

• Loans

• Charges

• Registered office

• Corporate resolutions

Layer 2: Quarterly Review

Reconcile:

• MCA master data

• Share capital

• Loans

• Charges

• Directors

• Shareholders

Layer 3: Half-Yearly Review

Review:

• MSME Form-1

• PAS-6 where applicable

• Other periodic compliance

Layer 4: Annual Review

Complete:

• Financial statements

• Audit

• AGM

• AOC-4

• MGT-7/MGT-7A

• Auditor-related filings

• Director KYC

• DPT-3

• Other applicable annual compliances

This four-layer system can make corporate compliance more manageable.

ROC Compliance Calendar for a Small Company

A small private company may use a simplified tracker:

April

MSE payment review.

May

Accounts and audit preparation.

June

DPT-3 preparation and filing where applicable.

July

Financial statement finalisation.

August

AGM preparation.

September

AGM and director compliance review.

October

AOC-4/MGT-7 follow-up and MSME Form-1 where applicable.

November–December

Annual filing reconciliation and event-based compliance review.

January

Mid-year ROC health check.

February

Year-end preparation.

March

Financial year-end and compliance review.

This is a planning framework, not a substitute for calculating each statutory due date.

What Should Management Review Every Quarter?

A quarterly ROC compliance meeting can cover:

• Any new director?

• Any director resignation?

• Any change in designation?

• Any new shares issued?

• Any transfer of shares?

• Any change in authorised capital?

• Any new loan?

• Any loan repaid?

• Any charge created?

• Any charge satisfied?

• Any registered office change?

• Any special resolution?

• Any MSE payment overdue?

• Any pending MCA form?

• Any resubmission?

• Any MCA notice?

This can take relatively little time but can identify issues before they become overdue filings.

Why Delhi NCR Businesses Should Maintain a Live Compliance Calendar?

Businesses in Delhi, Noida, Gurugram, Ghaziabad and Faridabad often deal with multiple registrations and financial institutions at the same time.

A single corporate event may affect:

• MCA

• GST

• Income Tax

• Banks

• PF/ESI

• IEC

• State registrations

• Licensing authorities

For example, changing the registered office may require the company to update more than just its MCA record.

Similarly, raising investment can trigger corporate, tax, accounting and regulatory documentation.

A live compliance calendar helps management identify these connections early.

Final Takeaway

A private limited company's ROC compliance should not be treated as a single annual task.

The company should maintain a year-round compliance calendar covering annual, half-yearly, director-specific and event-based requirements.

The core annual cycle generally includes:

Financial year closing → audit → Board approval → AGM → AOC-4 → MGT-7/MGT-7A

while other recurring or event-driven requirements can include:

DPT-3 → DIR-3 KYC → MSME Form-1 → PAS-6 → DIR-12 → PAS-3 → SH-7 → CHG-1 → CHG-4 → INC-22 → MGT-14

The distinction between these forms is important because they are triggered by different events and have different statutory timelines.

MCA's framework separately identifies annual filing forms such as AOC-4 and MGT-7/MGT-7A and event-driven forms such as DIR-12, CHG-1, MGT-14, INC-22, CHG-4 and SH-7.

The most practical approach is:

Track the event → identify the applicable form → calculate the statutory deadline → prepare supporting documents → file → preserve SRN/approval → update the internal compliance register.

For companies in Delhi, Noida, Gurugram, Ghaziabad, Faridabad and across India, this approach can make ROC compliance more predictable and reduce the risk of discovering missed filings only when the company needs funding, banking support, due diligence or regulatory documentation.

Need Help Managing ROC Compliance?

If your company needs assistance with annual ROC compliance, AOC-4, MGT-7/MGT-7A, DPT-3, MSME Form-1, DIR-12, PAS-3, SH-7, CHG filings or other MCA compliances, FilingSuvidha can help coordinate the applicable 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 only and should not be treated as legal, company-secretarial, accounting or professional advice. ROC/MCA compliance depends on the company's type, financial year, AGM date, transactions, shareholding, directors, borrowings and other facts. Statutory deadlines and MCA filing requirements can also change. Companies should verify the latest Companies Act provisions, MCA notifications, forms and applicable rules before filing.