MCA has given companies breathing room on annual filings this season. General Circular 05/2026, dated October 24, 2026, relaxes additional fees. AOC-4 variants can be filed till December 31, 2026. MGT-7 or MGT-7A can be filed till January 31, 2027. This helps teams closing FY 2025–26 audits and compliance. Students in CA firms should recalibrate immediate plans.
Important, this is a fee relaxation, not an AGM extension. Statutory AGM timelines under the Companies Act remain unchanged. Firms must still meet board approvals and internal sign-offs on time. Relief focuses only on specified e-forms for FY 2025–26. Misreading scope could invite penalties later.
MCA extension: AOC-4 and MGT-7 new fee-free dates
The circular lists each eligible form and the fee-free window. It covers AOC-4, AOC-4 CFS, AOC-4 XBRL, and NBFC Ind AS variants. Annual returns MGT-7 and MGT-7A share the longer window. Use this period to correct tagging and cross-check disclosures. Ensure XBRL instance documents align with the latest taxonomy version.
| Form category | Forms covered | Fee-free filing till |
|---|---|---|
| Financial statements | AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | December 31, 2026 |
| Annual return | MGT-7, MGT-7A | January 31, 2027 |
What the MCA extension does not cover
AGM timelines are outside this relief and continue to apply. Form ADT-1 for auditor appointment is not covered here. Director KYC and routine event-based filings are also unaffected. Treat this as a narrow window, not a blanket compliance holiday. Form ADT-1 still follows 15 days from AGM or appointment date.
CA firms’ immediate checklist for this week
Close audits and lock trial balances for final AOC-4 numbers. Complete XBRL tagging and validate against business rules. Generate UDINs and map them to reports and forms. Verify DIN KYC status, DSC validity, and signatory availability. Prepare board minutes, approvals, and ensure portal V3 readiness. Review shareholder and debenture data to match MGT-7 share capital schedules.
Common filing traps and how fees will apply
Late after these windows, all fees apply from the original due date. Example, a September 30 AGM makes AOC-4 due October 30. Miss January 31 for MGT-7, and additional fees back-calculate. Separate penalties under sections 92 and 137 may also apply. Fee slabs under the Registration Offices and Fees Rules will govern the charge.
Who benefits and how to schedule filings
SMEs and busy CA or CS practices gain most from staggered relief. Target AOC-4 by December 15 and MGT-7 by January 15. Keep two-week buffers for resubmissions and portal downtimes. Stage sign-offs to avoid bottlenecks across audit, board, and CFO. Stagger filings by client complexity, not by alphabetical lists.
Plan around the new dates now and avoid cramming in the final week. Students and articles can lead checklists, reconcile ledgers, and prepare XBRL runs. With disciplined scheduling, the MCA relief becomes a safety net, not a crutch. Mark December 31 for AOC-4 and January 31 for MGT-7, and work backward.
