2 min read
Several Registrar filings are not on a fixed date at all — they run from the day you hold your annual general meeting. Move the meeting and you move every deadline behind it.
Written by
Vagdev M RPartner · Finance and accountsThere is a persistent misreading of the Companies Act calendar: that AOC-4 is due on 29 October and MGT-7 on 28 November.
Those dates are only true for a company that holds its annual general meeting on 30 September, which happens to be the last permitted date for a company with a 31 March year end. Hold the meeting earlier — and plenty of companies do — and both deadlines move forward with it.
What runs from the meeting
| Filing | Window | What it carries |
|---|---|---|
| AOC-4 | 30 days from the AGM | Financial statements |
| MGT-7 or MGT-7A | 60 days from the AGM | Annual return |
| ADT-1 | 15 days from the appointment | Auditor appointment |
A company that holds its AGM on 12 August has AOC-4 due on 11 September, not in late October. Six weeks earlier than the date in most published calendars.
What does not
Two things in the same season are fixed to the calendar regardless of when you meet:
- DIR-3 KYC, 30 September, for every director holding a DIN. A lapse deactivates the DIN, which is a more disruptive outcome than the fee suggests — an inactive DIN cannot sign a filing.
- DPT-3, 30 June, the return of deposits and exempted receipts held on 31 March.
Why the late fee is the wrong thing to focus on
Registrar late fees run per day and they do not stop. There is no ceiling, which is unusual, and the arithmetic gets away from people: a filing that is nine months late is not nine times worse than one that is a month late in any intuitive sense, but it is exactly that in rupees.
The larger cost is usually elsewhere. A company with overdue filings cannot complete a bank facility, a due diligence exercise or a share transfer without first spending a fortnight putting the record straight. The fee is an irritation. The delay to the transaction is the real cost.
The practical version
Fix the AGM date at the start of the year rather than drifting toward the deadline, and put the two windows behind it in the calendar on the day you fix it. Everything else in the Registrar year follows from that one decision.
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