ROC & annual compliance for companies and LLPs

The Pvt Ltd year is driven by three anchors — 30 September (statutory audit + first Board Meeting to adopt accounts + DIR-3 KYC), 30 October (AOC-4 with audited financials, Directors' report, Auditor's report, MGT-9), and 29 November (MGT-7 annual return with shareholder list, board composition, indebtedness). DPT-3 by 30 June captures loans, deposits and inter-corporate advances outstanding as at 31 March.

Event-based filings sit on top — DIR-12 within 30 days of any director appointment or resignation, PAS-3 within 30 days of allotment of shares, CHG-1 within 30 days of creation of charge, INC-22 within 30 days of change in registered office, and MGT-14 within 30 days of any special resolution. Each carries ₹100/day late fee with no upper cap.

Every Director Identification Number (DIN) holder — including inactive DINs — must complete DIR-3 KYC by 30 September of every financial year. First-time and detail-change filings are done in DIR-3 KYC (with OTP + DSC + attestation); routine annual re-verification uses DIR-3 KYC WEB (simple OTP). Miss the deadline and the DIN is marked 'Deactivated due to non-filing of DIR-3 KYC' with a ₹5,000 reactivation fee.

A deactivated DIN cannot sign any MCA form — that includes AOC-4, MGT-7, INC-20A and every event-based form. In effect, one missed DIR-3 KYC freezes the entire company's compliance. Set a September calendar reminder for every director on every board, including LLP designated partners.

If a company fails to file financial statements or annual returns for three continuous financial years, every director on the board of that company is automatically disqualified under Section 164(2). The disqualification runs for five years and blocks that individual from being a director in any other company — often surfacing when they try to incorporate a new venture or take up a directorship elsewhere.

Recovery routes are limited: apply to NCLT for restoration, file Condonation of Delay Scheme (CODS) when notified, or resign from every board and wait out five years. Prevention is dramatically cheaper — even a shell / dormant company should file nil AOC-4 and MGT-7 every year for ₹500 in professional fees to protect director credentials.