ROC Annual Filing Checklist for Private Limited Companies

Key Takeaways

AOC-4 is due within 30 days and MGT-7/MGT-7A within 60 days of the AGM.

DIR-3 KYC is an annual obligation for every director holding a DIN, even in a dormant company.

Late ROC filing attracts an additional fee of ₹100 per day per form, with no cap.

A deactivated DIN blocks the director from signing any form for any company.

ROC compliance is unforgiving in one specific way: the additional fee for late filing runs at ₹100 per day per form and does not stop. A form forgotten for a year is not a small penalty — it is a five-figure one, per form, per company.

Who this covers
This checklist is for a private limited company that is not a small company exception case. One Person Companies and small companies file MGT-7A instead of MGT-7 and have a lighter board meeting requirement.

The annual sequence

Close the books and get the financial statements ready for audit.
Board meeting to approve the financial statements and the board's report.
Statutory audit completed and the audit report signed.
Annual General Meeting held within six months of financial year end (nine months for the first AGM).
File AOC-4 with the financial statements within 30 days of the AGM.
File MGT-7 or MGT-7A with the annual return within 60 days of the AGM.
File DIR-3 KYC for every director by the annual deadline.

Form-by-form reference

Form	Purpose	Timeline
AOC-4	Financial statements and board's report	30 days from AGM
MGT-7 / MGT-7A	Annual return	60 days from AGM
DIR-3 KYC	Director KYC for each DIN holder	Annual, by the notified date
ADT-1	Auditor appointment	15 days from AGM (on appointment)
MSME-1	Half-yearly return of dues to MSME vendors	Half-yearly
DPT-3	Return of deposits and exempted receipts	Annual

The recurring filings most private companies need

The DIN trap
Miss DIR-3 KYC and the director's DIN is deactivated. That director then cannot sign any form for any company until the KYC is filed with the reactivation fee — which usually surfaces at the worst possible moment, mid-transaction.

Registers and records to keep current

Register of members, directors and key managerial personnel.
Register of charges, kept in step with every loan and security created.
Minutes of board and general meetings, signed and paginated.
Statutory registers available at the registered office for inspection.

Do it in one sitting
Block a single week after the AGM for the entire filing set. Splitting it across months is how the second and third forms get forgotten.

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Frequently Asked Questions

What is the penalty for late ROC filing?

An additional fee of ₹100 per day per form applies from the due date until the date of actual filing, with no upper limit. Continuing default can also attract penalties on the company and its officers under the relevant section.

Does a dormant or zero-revenue company still have to file?

Yes. Annual filings and DIR-3 KYC are required regardless of turnover. A company with no operations still files AOC-4 and MGT-7A, and its directors still complete KYC.

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

MGT-7A is the abridged annual return prescribed for One Person Companies and small companies. Other companies file MGT-7. The content of the abridged form is lighter but the deadline is the same.

Disclaimer: This article is for general information only and is not professional advice. Tax and regulatory positions change frequently — please consult Carvi Associates before acting on anything you read here.