MCA MGT-7 Annual Return: 60-Day Filing Window Plus Director Annual KYC Deadline

Indian companies enter the busiest stretch of the corporate compliance calendar between June and November every year, and Form MGT-7 sits at the centre of it. Filed under Section 92 of the Companies Act 2013, the annual return must reach the Registrar of Companies (RoC) within 60 days of the annual general meeting (AGM). With the June 2026 monetary cycle behind us and AGM season for FY 2025-26 approaching its 30 September 2026 statutory ceiling, directors and company secretaries should pin the MGT-7 and DIR-3 KYC dates to the wall now rather than scramble in November.

This watchlist covers the statutory filings that govern the next working day and the weeks ahead, the market event that closed the week, and what an investor or promoter should track. Every figure below is drawn from the Companies Act 2013 and Ministry of Corporate Affairs (MCA) e-filing rules, not from estimates.

Statutory Deadlines

The headline obligation is Form MGT-7, the annual return mandated by Section 92 of the Companies Act 2013. Every company other than a One Person Company and small company must file it within 60 days from the date of its AGM. Because Section 96 requires the AGM for FY 2025-26 (year ended 31 March 2026) to be held by 30 September 2026, a company that convenes its AGM on that last permissible day has until 29 November 2026 to file MGT-7. As 29 November 2026 falls on a Sunday, the operative deadline rolls to the next working day, 30 November 2026.

Small companies and One Person Companies file the lighter Form MGT-7A, introduced by the MCA in March 2021. It strips out several disclosures that full-form filers must complete, but the 60-day clock from the AGM date applies identically. A One Person Company, which is not required to hold an AGM, counts the 60 days from the date its sole member signs and dates the financial statements.

The penalty design is what makes MGT-7 unforgiving. Under Section 92(5), a default attracts a flat penalty of Rs 100 per day with no upper ceiling. A company that files 100 days late therefore pays Rs 10,000, and both the company and every officer in default are separately liable. There is no cap, unlike many other Companies Act penalties, so delay compounds in a straight line.

Running alongside MGT-7 is the DIR-3 KYC obligation for directors. Every person who holds a Director Identification Number (DIN) allotted on or before 31 March 2026, and whose DIN is in approved status, must complete annual KYC with the MCA by 30 September 2026. Where contact details are unchanged from the previous year, the director files the simpler web-based service DIR-3 KYC-WEB; where the mobile number or email has changed, the full DIR-3 KYC e-form is mandatory. A valid Digital Signature Certificate (DSC) of the director is required either way.

Miss the 30 September window and the consequence is immediate: the DIN is marked Deactivated due to non-filing of DIR-3 KYC, and reactivation requires filing the form with a Rs 5,000 fee. A deactivated DIN blocks the director from signing any subsequent statutory filing, which can stall the company's own MGT-7 and AOC-4 submissions.

Note that AOC-4, the financial-statement filing under Section 137, is due within 30 days of the AGM, so it precedes MGT-7 by a month. A company holding its AGM on 30 September 2026 must file AOC-4 by 30 October 2026 and MGT-7 by 30 November 2026. The two are sequential, not simultaneous, and both carry the same Rs 100-per-day default penalty.

Market Events

The Reserve Bank of India's Monetary Policy Committee concluded its scheduled review across 3 to 5 June 2026, the meeting that follows the 6 to 8 April 2026 session at which the repo rate was held at 5.25%. The April pause was the second consecutive hold and came after a cumulative 125 basis points of easing through 2025 that took the policy rate down from 6.50% to 5.25%. Investors digesting the June decision should read it against the corridor the RBI published in April: the Standing Deposit Facility (SDF) rate at 5.00%, the Marginal Standing Facility (MSF) and Bank Rate both at 5.50%.

The repo rate matters to corporate borrowers because external benchmark lending rate (EBLR) linked floating loans reset within roughly three months of any change, so working-capital costs for the companies now finalising annual accounts move in step. Readers tracking how the rate corridor feeds into deposit and loan pricing can review the mechanics on our repo rate glossary entry. For context on how the financial year boundary of 31 March 2026 frames every one of these filings, see the financial year explainer.

For investors, the practical link between the compliance calendar and portfolio decisions runs through disclosure quality. A company that files MGT-7 and AOC-4 on time signals governance discipline, and these filings are the public record of shareholding patterns and board composition. Systematic investors building positions ahead of results season can model contributions using our SIP calculator or compare a one-time deployment with the lumpsum calculator.

Earnings

No company-specific results were confirmed in the editorial briefing for the next session, so this watchlist does not publish a speculative earnings calendar. Indian listed companies disclose board-meeting dates for results through the stock exchanges under SEBI's Listing Obligations and Disclosure Requirements, and those notices are the only reliable source for a results schedule. Verify any specific date directly on the BSE or NSE corporate-announcements page before trading on it.

What is verifiable is the structural overlap between earnings season and the MCA filing window. Listed companies must hold their AGM for FY 2025-26 by 30 September 2026 under Section 96, and the annual report circulated at that AGM contains the audited financials that also underpin the AOC-4 filing due 30 days later. The MGT-7 annual return, due a further 30 days after that, records the post-AGM shareholding pattern. For investors stepping up commitments through a results season, the step-up SIP calculator models an annual escalation in contributions, and those building a tax plan around advance-tax instalments should review the advance tax glossary entry since the second instalment of 45% cumulative liability falls due on 15 September 2026, just ahead of AGM season.

FAQ

What is the due date for filing Form MGT-7 for FY 2025-26?

MGT-7 must be filed within 60 days of the AGM under Section 92 of the Companies Act 2013. If a company holds its AGM on the last permissible day of 30 September 2026, the MGT-7 deadline is 29 November 2026, which rolls to 30 November 2026 as 29 November is a Sunday. The exact date depends on when the individual company actually holds its AGM.

What is the difference between MGT-7 and MGT-7A?

MGT-7 is the full annual return filed by most companies, while MGT-7A is the abridged form introduced by the MCA in March 2021 for One Person Companies and small companies. MGT-7A omits several disclosures but follows the same 60-day filing window from the AGM date. A One Person Company counts the 60 days from when its sole member signs the financial statements.

What is the penalty for late filing of MGT-7?

Section 92(5) imposes a penalty of Rs 100 per day of default with no upper limit. Both the company and every officer in default are separately liable. Because there is no cap, a 100-day delay alone costs the company Rs 10,000, and the figure keeps rising in a straight line until the return is filed.

When is the DIR-3 KYC deadline and what happens if I miss it?

DIR-3 KYC is due annually by 30 September for every DIN holder whose number was allotted on or before 31 March of that year. Missing 30 September 2026 deactivates the DIN for non-filing, and reactivation requires filing the form with a Rs 5,000 fee. A deactivated DIN cannot sign any statutory filing until it is restored.

Do I need a Digital Signature Certificate for these filings?

Yes. A valid Digital Signature Certificate (DSC) of the director is mandatory for both DIR-3 KYC e-form and MGT-7. Directors who use the web-based DIR-3 KYC-WEB service still authenticate through the DSC and a one-time password, so an expired DSC must be renewed before the 30 September 2026 deadline.

Is AOC-4 due before or after MGT-7?

AOC-4, the financial-statement filing under Section 137, is due within 30 days of the AGM, while MGT-7 is due within 60 days. AOC-4 therefore precedes MGT-7 by one month. For an AGM held on 30 September 2026, AOC-4 is due 30 October 2026 and MGT-7 is due 30 November 2026.

Does the repo rate decision affect company compliance costs?

Indirectly, yes. The RBI held the repo rate at 5.25% in April 2026, and EBLR-linked floating loans reset within roughly three months of any change. A company finalising FY 2025-26 accounts sees its interest cost on working-capital borrowings track the prevailing 5.25% corridor, which feeds into the financials disclosed in AOC-4 and summarised at the AGM.