India’s Ministry of Corporate Affairs has given companies breathing room on annual filings. Vide General Circular No. 05/2026 dated October 24, 2026, AOC‑4 variants can be filed without additional fees until December 31, 2026, while MGT‑7 or MGT‑7A can be filed until January 31, 2027. This limited waiver matters for finance teams and crowded CA offices now.
The relief covers filings for the financial year 2025–26 only and includes AOC‑4, AOC‑4 CFS, AOC‑4 XBRL, and NBFC Ind AS variants. It is a relaxation of additional fees, not an Annual General Meeting extension. Normal filing fees still apply, but the late fee component is waived within the window.
MCA extends AOC‑4 deadline: what exactly changes now
Statutory law still ties AOC‑4 to thirty days from the AGM date. Many companies held AGMs by September 30, 2026, making AOC‑4 originally due by October 30. Under the circular, filings done by December 31 avoid additional fees; after that, extra fees apply from the original due date, not from January 1.
MGT‑7 and MGT‑7A new due date: who is covered
MGT‑7 applies to most companies; MGT‑7A serves One Person and small companies. Both annual return forms can be filed without additional fees up to January 31, 2027, for FY 2025–26. The AOC‑4 family’s relief runs only until December 31, 2026, so plan sequencing accordingly.
CA and CS firm filing playbook for the fee‑free window
Freeze internal calendars this week, with staggered cut‑offs by client size. Renew expiring Digital Signature Certificates, and keep Unique Document Identification Number (UDIN) generation queues ready. Finish XBRL tagging, attach signed audit reports, and run pre‑scrutiny well before upload. Pre‑validate director DINs, authorised signatory roles, and paid‑up capital data to avoid last‑day portal stress.
Important AOC‑4 and MGT‑7 dates students and teams must remember
| Form | Statutory due (typical AGM Sep 30) | Fee‑relaxation window | After window |
|---|---|---|---|
| AOC‑4 (all variants) | October 30, 2026 | Till December 31, 2026 | Additional fees apply from original due date |
| MGT‑7 / MGT‑7A | November 29, 2026 | Till January 31, 2027 | Additional fees apply from original due date |
The circular waives additional fees only; statutory timelines remain under the Companies Act.
Missed the new dates? Know the costs and the clock
Filings made after December 31 or January 31 attract all applicable charges. The additional fee meter is computed from when each form was first due, not from the relief window’s end. Prolonged non‑compliance can trigger adjudication, so quantify exposure early and document reasonable cause.
For commerce students, articled assistants, and compliance job seekers, this is a live case study in regulatory planning. Mark December 31, 2026 for AOC‑4 and January 31, 2027 for MGT‑7 or MGT‑7A on your tracker. Use the window to file cleanly, avoid last‑minute backlogs, and build reliable compliance habits for your career.
