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    MCA Extends AOC-4 to 31 December 2026 and MGT-7 to 31 January 2027

    October 28, 2026 · Article · 5 min read

    Before using the extra time, check MSME-1, ADT-1 and any LLP's Form 8, whose dates did not move. If your accounts are ready, file them anyway.

    At a glance

    What changed
    Companies may file 2025-26 financial statements (AOC-4 and its variants) until 31 December 2026, and annual returns (MGT-7 and MGT-7A) until 31 January 2027. Neither attracts additional fees in that time.
    In force from
    24 October 2026, the date of the circular. It covers filings for the 2025-26 financial year.
    Not extended
    MSME-1 for April to September 2026, due 31 October. ADT-1, due 15 days after the AGM that appointed the auditor. LLP Form 8, due 30 October. Nor is the time to hold the AGM.
    Status
    In force. The fee-free window closes on 31 December 2026 for AOC-4 and on 31 January 2027 for MGT-7 and MGT-7A.
    Source
    MCA General Circular No. 05/2026; see MCA's general circulars page.

    What did MCA extend, and to when?

    The Ministry of Corporate Affairs has relaxed the additional fee on the year's two main annual filings. Under General Circular No. 05/2026, companies may file 2025-26 up to 31 December 2026 without additional fees. Annual returns get until 31 January 2027 on the same terms.

    Financial statements go in Form AOC-4. The circular also lists its consolidated and XBRL versions, and two versions for non-banking financial companies that report under Indian Standards (Ind AS). Annual returns go in MGT-7, or MGT-7A for small companies and one person companies.

    Without the circular, both deadlines run from the annual general meeting (AGM), or from the date it should have been held. AOC-4 is due within 30 days of it and MGT-7 within 60. A company that met on 30 September was looking at 30 October and 29 November. A one person company holds no AGM and files AOC-4 within 180 days of the year-end.

    The AGM itself does not move. The circular says it confers no extension of the statutory time for holding one. The annual compliance guide for private limited companies sets out the rest of the year.

    Which companies does it help, and which filings stay due?

    Every company filing financial statements or an annual return for 2025-26 gets the later dates. The circular carves out no class of company.

    Three filings due in October sit outside it, one of them for limited liability partnerships (LLPs). The circular names only the AOC-4 forms and the annual return forms, so these keep their usual dates.

    MSME-1 is due on 31 October. It is a half-yearly return from companies whose payments to micro or small suppliers run beyond 45 days from accepting the goods or services. This one covers April to September 2026.

    ADT-1 is due 15 days after the AGM that appointed the auditor. A company that met on 30 September had until 15 October. A company that met later, under an extension from the Registrar, counts from its own meeting.

    LLP Form 8 is due on 30 October. It is the statement of account and solvency, filed within 30 days after the first half of the financial year. An LLP owes it whether or not it traded. This circular is issued under the Companies Act, so it does not reach LLPs. The guide to LLP annual compliance covers both of an LLP's annual forms.

    What does it cost to miss the old dates or the new ones?

    Filing AOC-4 by 31 December or MGT-7 by 31 January costs no additional fee. The circular attaches a condition. A form filed after the window pays every fee due, counted from the original due date, as if the extension had never been granted.

    Overdue payments carry a tax cost as well as a filing. An amount owed to a registered micro or small supplier beyond the statutory period is deductible only in the year it is actually paid. The Income-tax Act 2025, in force since 1 April 2026, keeps that rule. So one invoice still unpaid at the year-end can mean a return to file and a deduction pushed into a later year. The guide for MSME owners explains the 45-day limit.

    An LLP that misses Form 8 pays an additional fee on each late form. It rises in steps with the delay, and after a year a charge is added for every further day, with no cap. It keeps running until the form is filed, whether or not the LLP earned anything. The LLP Act adds a penalty of its own for each return not filed, counted per day.

    What should companies and LLPs do before 31 October?

    At SRF Capital Studio, we treat an extension as time to finish the work. The filing still has to be made, and once the window closes the original due date still sets the fee.

    Miss the new date and the fee counts from the old one.
    1. File now if the accounts are ready. If the AGM has adopted them, file AOC-4 this week and MGT-7 soon after. The extra time helps companies whose filings are not ready. It does not cure a late AGM.
    2. Test MSME-1 before deciding it does not apply. Pull every micro or small supplier from the ledger and check each payment against 45 days from acceptance. If any crossed it, file by 31 October.
    3. Confirm the ADT-1 date from the AGM minutes. Count 15 days from the meeting that appointed or reappointed the auditor. If that day has passed, file now.
    4. File Form 8 for every LLP, including the quiet ones. An LLP with no business still owes the form, and its designated partners still sign the solvency statement.
    5. Put the new dates in the diary. AOC-4 by 31 December 2026; MGT-7 or MGT-7A by 31 January 2027. Recurring dates are in the Compliance Calendar.

    What is still to be confirmed?

    The circular is clear on what it extends. It leaves two questions open.

    Whether ADT-1 gets relief of its own. The circular does not mention it. Until MCA says otherwise, the 15-day rule stands.

    Whether additional fees already paid come back. A company that held its AGM early and filed late may already have paid them. The circular says nothing about refunds.

    Which documents set these dates?

    MCA General Circular No. 05/2026, dated 24 October 2026, relaxes additional fees and extends the time to file 2025-26 financial statements and annual returns. MCA publishes its circulars on its general circulars page.

    MSME-1 rests on the Specified Companies (Furnishing of information about payment to micro and small enterprise suppliers) Order, 2019, made under section 405 of the Companies Act. Its paragraph 3 sets 31 October for April to September.

    ADT-1 follows the proviso to section 139(1) of the Companies Act and rule 4(2) of the Companies ( and Auditors) Rules, 2014. LLP Form 8 follows rule 24(4) of the Limited Liability Partnership Rules, 2009.

    Frequently asked questions

    Is the AGM deadline extended too?

    No. The circular extends the time to file, and says it does not extend the time for holding an AGM.

    Does General Circular 05/2026 cover ADT-1?

    No. It covers the AOC-4 forms, MGT-7 and MGT-7A. ADT-1 is still due within 15 days of the AGM that appointed the auditor.

    Does the extension apply to LLP Form 8?

    No. Form 8 is an LLP filing under the LLP Rules. For a financial year ending 31 March, it is due on 30 October 2026.

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