- Circular
- MCA General Circular No. 05/2026, dated 24 Oct 2026
- AOC-4 (financials)
- FY 2025-26 — now up to 31 Dec 2026
- MGT-7 / 7A (annual return)
- FY 2025-26 — now up to 31 Jan 2027
- The catch
- No AGM extension; late-filing fees run from the original due date
The short version
- The MCA has extended the FY 2025-26 annual filing deadlines for companies under the Companies Act, 2013, via General Circular No. 05/2026 (24 October 2026) — with no additional fees if filed within the extended window.
- Financial statements — AOC-4 and its variants (AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS)) — can now be filed up to 31 December 2026.
- Annual returns — MGT-7 and MGT-7A — can now be filed up to 31 January 2027.
- Two things the relief does not do: it does not extend the timeline for holding the AGM, and if you file after this window closes, additional fees are charged from the original due date — not from the extended date.
If you have company annual filings pending for FY 2025-26, there's welcome breathing room. The Ministry of Corporate Affairs has issued General Circular No. 05/2026, pushing back the due dates for financial statements and annual returns and waiving the additional (late) fees for filings made within the extended window. It follows representations from stakeholders who asked for more time — and, as in the previous year, the MCA has obliged. But the relief comes with two important conditions that are easy to miss. Here's exactly what's been extended, who it applies to, and the fine print that still bites.
What exactly has been extended?
The circular allows companies to file two sets of annual forms for the financial year 2025-26 beyond their normal due dates, without payment of additional fees:
| Filing | Forms covered | Extended due date |
|---|---|---|
| Financial statements | AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | 31 December 2026 |
| Annual returns | MGT-7, MGT-7A | 31 January 2027 |
In short: the whole AOC-4 family (standalone, consolidated, XBRL and the NBFC Ind-AS variants) gets until the end of December 2026, and the annual return forms get an extra month, until the end of January 2027.
A quick refresher — what are these forms?
- AOC-4 is the form for filing a company's financial statements (balance sheet, profit & loss, auditor's report, board's report) with the Registrar of Companies. Companies meeting XBRL criteria file AOC-4 XBRL; companies with subsidiaries file consolidated statements in AOC-4 CFS; NBFCs reporting under Ind AS use the NBFC variants.
- MGT-7 is the annual return — a yearly snapshot of the company's shareholding, directors, and key particulars. MGT-7A is the abridged annual return for One Person Companies (OPCs) and small companies.
Normally, AOC-4 is filed within 30 days of the Annual General Meeting (AGM) and MGT-7/7A within 60 days of the AGM. For most companies whose AGM was held by 30 September 2026, that meant AOC-4 falling due around end-October and the annual return around end-November. This circular moves those effective cut-offs to 31 December 2026 and 31 January 2027 respectively — fee-free.
The money part: what "no additional fees" actually saves
Late MCA filings normally attract an additional fee of ₹100 per day, per form, with no upper cap — which adds up fast across AOC-4 and MGT-7 for even a short delay. The circular waives that additional fee for FY 2025-26 filings made within the extended dates. For companies that were running behind, that's a direct, meaningful saving.
Read the fine print — fees run from the ORIGINAL due date if you miss the window
This is the part that trips people up. The circular clarifies that any filing made after the currency of this relief will attract all fees, including additional fees, calculated from the date the filing was actually due under the Act — not from 31 December 2026 or 31 January 2027. So the extension is a fee-free grace period only if you file within it. Miss it, and the ₹100/day clock is treated as having run from your original AGM-linked due date, wiping out the benefit. Don't treat the new dates as a comfortable buffer.
Critical caveat: the AGM deadline is NOT extended
The circular is explicit on this. It shall not be construed as extending the statutory time for holding AGMs. Companies that did not hold their AGM within the timelines prescribed under the Companies Act, 2013 remain liable under the relevant provisions. This relief is purely about the filing of forms and the additional fees on those forms — it does nothing for a delayed or un-held AGM.
Why this distinction matters
A company could validly use the extra time to file AOC-4 and MGT-7 without additional fees, yet still be exposed to separate consequences if its AGM itself was late or not held on time. If you were relying on an AGM extension, this circular does not give you one — you'd need to have applied to the Registrar for that separately. If in doubt about your AGM position, get it reviewed before assuming you're fully covered.
Who does this apply to?
The relief is for companies filing annual statutory forms under the Companies Act, 2013 for FY 2025-26 — private limited companies, public companies, OPCs, small companies and the covered NBFCs. If your company has an AOC-4 or MGT-7/7A obligation for FY 2025-26, you're within scope. (Note that LLPs file Form 8 and Form 11 under the LLP Act on their own timelines — this particular circular addresses Companies Act forms.)
What you should do now
- Confirm your AGM is sorted. The filing extension assumes your AGM position is in order. Verify the AGM was held within time (or that you had a separate extension) before relying on the new dates.
- Finalise accounts and audit. Use the extra time to get financial statements audited and board/AGM documents in order — don't let the deadline creep up.
- File AOC-4 by 31 December 2026. Lodge financial statements (the right AOC-4 variant for your company) well before the cut-off to avoid last-minute portal congestion.
- File MGT-7 / MGT-7A by 31 January 2027. Lodge the annual return within its extended window.
- Don't slide past the window. Remember — file late and fees are charged from your original due date, not the extended one. Treat these as hard deadlines, not soft ones.
Frequently asked
What is the new due date for AOC-4 for FY 2025-26?
What is the new due date for MGT-7 and MGT-7A for FY 2025-26?
Does this circular extend the time for holding the AGM?
What happens if I file after 31 December 2026 / 31 January 2027?
How much is the additional fee being waived?
Does this apply to LLP filings (Form 8 and Form 11)?
Pending company annual filings for FY 2025-26?
efiletax handles AOC-4, MGT-7 and the full ROC annual compliance set — accounts, audit coordination and timely filing — so you use the extension correctly and never get caught by fees running from the original due date.
Talk to our ROC teamDisclaimer: This article summarises MCA General Circular No. 05/2026 dated 24 October 2026, extending the time for filing financial statements (AOC-4 and variants) to 31 December 2026 and annual returns (MGT-7 / MGT-7A) to 31 January 2027 for FY 2025-26 without additional fees, under the Companies Act, 2013. It is provided for general understanding and is current as at the date of publication; please refer to the official circular on the MCA website and verify form applicability and due dates for your company before filing. The relief does not extend AGM timelines. This is not legal or professional advice — please consult a qualified professional. Talk to efiletax if you need help.