Last reviewed: 4 September 2026
Quick answer: Every registered company must file its financial statements (Form AOC-4) within 30 days of the AGM and its annual return (Form MGT-7) within 60 days of the AGM. Both carry a late fee of ₹100 per day, with no upper cap, on top of separate penalties for continued non-filing.
ROC compliance is often the first thing that slips once a company is focused on operations — not because it’s complicated, but because the deadlines are easy to lose track of against an AGM date that shifts year to year. Here’s the factual position on the two core annual filings, and what else falls under secretarial compliance.
Annual ROC filings
| Form | Due date | Late fee | Non-filing penalty |
|---|---|---|---|
| AOC-4 (financial statements) | Within 30 days of the AGM | ₹100/day, no upper cap | ₹1,000/day, up to ₹10 lakh for the company; officers in default also face penalties |
| MGT-7 (annual return) | Within 60 days of the AGM | ₹100/day, no upper cap | ₹50,000 plus ₹100/day, up to ₹5 lakh for the company; officers in default also face penalties |
Because the late fee accrues per day with no cap, the cost of a missed AOC-4 or MGT-7 filing grows the longer it’s left — resolving it as soon as it’s noticed is materially cheaper than waiting for the next filing cycle.
What else falls under secretarial compliance
- Director changes — appointment, resignation, or change in designation, each with its own ROC form and filing window.
- Shareholding changes — transfer or allotment of shares, and the corresponding filings to keep the company’s register and ROC records aligned.
- Statutory registers and minutes — maintaining the registers a company is required to keep under the Companies Act, and board/AGM minute documentation.
- Ongoing filing calendar — tracking AGM dates and every downstream deadline they trigger, rather than reacting once a due date has passed.
Questions we’re asked about ROC compliance
We haven’t held an AGM yet this year — does the AOC-4/MGT-7 clock start from the AGM or the financial year-end?
Both deadlines run from the AGM date, not the financial year-end — AOC-4 within 30 days of the AGM, MGT-7 within 60 days. Holding the AGM on time is itself a separate compliance requirement that indirectly sets both filing clocks.
We missed the AOC-4 deadline last year — what happens now?
The ₹100/day late fee has been accruing since the deadline passed and has no upper cap, so it’s worth filing as soon as possible rather than waiting. Prolonged non-filing carries a further penalty on the company and its officers, separate from the daily late fee.
Does a small or dormant private company still need to file AOC-4 and MGT-7?
Yes — these filings apply to every registered company regardless of size, turnover, or activity level. A dormant company has a separate status it can apply for under the Companies Act, but that doesn’t remove the annual filing requirement on its own.
Behind on ROC filings, or need to plan this year’s AGM and filing calendar? Ask us on WhatsApp