MCA & Compliance

MCA Annual Filing Extension 2026: AOC-4 and MGT-7 Dates Explained

MCA confirms FY 2025–26 filing relief: AOC-4 forms up to 31 December 2026 and MGT-7/MGT-7A up to 31 January 2027. Compare the scope and prepare your filing records.

NRS Editorial Desk · Published 2026-10-24 · 8 min read

MCA has announced an annual filing extension for FY 2025–26 through General Circular No. 05/2026, dated 24 October 2026. Its official announcement gives 31 December 2026 for the listed AOC-4 financial-statement forms and 31 January 2027 for MGT-7 and MGT-7A annual returns, with relaxation of additional fees. Keep the two filing windows separate.

For company directors, the practical distinction is straightforward: there are two filing windows, but neither makes an overdue AGM compliant. Normal filing fees, accurate accounts and the correct annual-return disclosures still need attention.

This guide is for directors and finance teams across India. It explains the covered forms, what the relief leaves unchanged and how to organise a complete filing pack. The national conditions also apply to Kerala companies; local support options appear below.

What are the extended AOC-4 and MGT-7 filing dates?

The relief is for the forms and financial year identified in the circular. A company must select the form applicable to its own reporting obligations; extra time does not make the forms interchangeable.

Do not use the January date for AOC-4. Financial statements and annual returns have separate end dates under this relief. Record both in the compliance calendar and assign responsibility for each.

Does “without additional fees” mean filing is free?

No. The circular addresses additional fees for the covered filings. It does not describe a general waiver of normal filing fees, professional charges or liabilities arising from unrelated defaults.

Keep three items separate in the working: the normal statutory filing fee, the additional fee treatment for the covered form and period, and any separate compliance default requiring advice. A single line saying “all penalties waived” would misstate the relief.

Paragraph 4 continues onto page 2: filings made after the relief period attract all applicable fees, including additional fees, from the date the filing was originally due under the Companies Act. The extension does not reset the additional-fee clock. A company filing after its applicable relief window must calculate exposure from the original statutory due date, not only from 1 January or 1 February 2027.

Has the AGM deadline also been extended?

No. Paragraph 3 expressly separates this filing relaxation from the statutory time for holding AGMs. Companies that have not complied with the relevant AGM timelines remain subject to the applicable provisions of the Companies Act.

Create two separate entries in the file: meeting compliance and filing compliance. For the first, retain the actual meeting date, approvals and any independently valid extension. For the second, record the applicable form, financial year, submission and payment evidence.

If the AGM was not held, was adjourned or did not adopt the accounts, the filing route needs its own review. Do not insert an invented meeting date to make a form validate. Extra filing time cannot correct an inaccurate corporate record.

Which filings should not be assumed to receive this relief?

The circular's covered-form list does not name LLP Form 8, LLP Form 11, ADT-1, DPT-3, MSME-1, tax returns, GST returns or PF returns. Each must be checked under its own requirements and any separate relief.

Likewise, the stated financial year is FY 2025–26. A pending return for an older year should not be moved into this window merely because it uses the same form name. Prepare an older-year backlog separately rather than treating the announcement as a general amnesty.

This is also a different issue from the Companies Compliance Facilitation Scheme covered in our CCFS guide. That guide addresses its own scheme conditions; this article concerns the identified annual filings for FY 2025–26.

What should companies do now? A practical filing checklist

• Identify the company and reporting period. Confirm the CIN, legal name, financial year and which financial-statement and annual-return forms apply.
• Check meeting records. Record the actual AGM position and flag any separate default or unresolved adoption issue.
• Complete the accounts pack. Assemble approved financial statements, the auditor's report, Board's report and other attachments required for the applicable filing.
• Reconcile the annual return. Check directors, members, share capital, transfers and other relevant disclosures against the underlying registers and records for the reporting period.
• Review consolidated or specialised reporting. Resolve CFS, XBRL and NBFC applicability before preparing the wrong form.
• Test filing readiness. Check the authorised signatories, DSC validity, MCA account access, required professional certification and attachment quality.
• Submit and complete payment. Track the SRN and the actual submission/payment status. A saved draft is not evidence of completed filing.
• Close the file. Retain submitted forms, signed attachments, challans, acknowledgements and any resubmission correspondence together.

Use the additional time to fix discrepancies between records and disclosures. Waiting until the final day leaves little room to resolve a rejected attachment, signature problem or payment issue.

Example: two filing windows, one company file

Consider an illustrative private company with an AGM already held and FY 2025–26 accounts ready. It needs an applicable AOC-4 filing and an annual return in MGT-7. Under the relief, its financial-statement filing window ends on 31 December 2026; its MGT-7 window ends on 31 January 2027.

The useful action is to finish the accounts filing and reconcile the annual return alongside it, with an internal completion date ahead of both cut-offs. There is no requirement to wait until January to finish the annual return.

Change one fact: the AGM itself was late. The same filing-window analysis does not resolve the separate meeting default. That issue must remain visible in the review even if the portal accepts a filing without additional fees.

These are planning examples, not descriptions of NRS client outcomes or assurances that a particular filing will be accepted.

ROC annual filing support in Kozhikode, Manjeri and Malappuram

The legal requirements are national. What a local company often needs is a coordinated review of its accounts, meeting records and annual-return data before submission.

For a trading company in Kozhikode, that may involve reconciling capital and director information with the financial statements. For a company managed from Manjeri or elsewhere in Malappuram district, it may involve organising records held by different directors or finance staff. These are practical examples of preparation needs, not separate regional filing concessions.

NRS can discuss the required scope through its Calicut (Kozhikode) office or Manjeri office, including businesses across the Malappuram district service area.

For a first enquiry, provide the company name, reporting year, pending forms and current AGM/filing status. The team can then identify the documents needed for a scoped company compliance review. Use the contact page to arrange the discussion; do not include portal passwords, OTPs or DSC credentials in an enquiry.

Frequently asked questions

Has MCA extended annual filing for FY 2025–26?

Yes. MCA’s official 24 October 2026 announcement confirms Circular 05/2026 and identifies 31 December 2026 for the listed AOC-4 forms and 31 January 2027 for MGT-7 and MGT-7A. These are different filing windows for financial statements and annual returns; check the form and financial year before relying on the relief.

What is the AOC-4 last date under MCA Circular 05/2026?

The relief permits the listed FY 2025–26 AOC-4 variants to be filed up to 31 December 2026 without additional fees. Check that the company's form and financial year fall within the circular.

What is the extended MGT-7 and MGT-7A last date?

The extended date for FY 2025–26 MGT-7 and MGT-7A is 31 January 2027. It is a separate window from the financial-statement forms.

Can AOC-4 also be filed until 31 January 2027?

That January date belongs to MGT-7 and MGT-7A in the circular's list. The listed AOC-4 forms have a 31 December 2026 end date.

Does the circular extend the AGM date?

No. Paragraph 3 expressly says the circular does not extend statutory AGM timelines. Meeting compliance must be checked separately.

What happens if AOC-4 or MGT-7 is filed after the extended date?

Paragraph 4 says filings after the relief period attract applicable fees, including additional fees, from the original date when the filing was due under the Companies Act. Do not calculate the delay only from the extended cut-off. The amount depends on the applicable form, original due date and actual filing date.

Does the relief apply to LLP Form 8 or older annual returns?

The relief covers the listed company forms for FY 2025–26. Do not assume it covers LLP filings or older financial years without a separate applicable provision.

Does the relief apply throughout India, including Kerala?

A company must meet the specified form, financial-year and other conditions regardless of its state. The relief is not restricted to Kerala, and there is no separate Kozhikode, Manjeri or Malappuram filing window.

Should a company that already filed submit the same return again?

An extension alone is not a reason to duplicate a completed filing. Check the existing SRN, payment and processing status; address an actual error or resubmission requirement through the applicable route.