MCA Extends Annual Filing: AOC-4 Now Fee-Free Till 31 December, MGT-7 Till 31 January

Three weeks ago I wrote here that ICSI's request to the MCA was just that — a request, not a decision. On 24 October, the decision arrived. The Ministry of Corporate Affairs has issued General Circular No. 05/2026, and for once the headline is true: annual filing for FY 2025-26 just got cheaper to be late with.

The short answer: Under General Circular No. 05/2026 dated 24 October 2026, companies can file FY 2025-26 financial statements in AOC-4 and its variants up to 31 December 2026, and annual returns in MGT-7 or MGT-7A up to 31 January 2027, without additional fees. The normal fee still applies, AGM deadlines have not moved, and LLPs get nothing from this circular.

That is the good news, and it is real. But a fee waiver is a narrower thing than an extension, and the difference will cost some companies money. Here is the circular read properly — what it grants, what it pointedly does not, and the one filing it leaves completely untouched, due in four days.

What exactly has been extended?

Strictly speaking, nothing has been "extended". The statutory due dates in the Companies Act are exactly where they were. What General Circular No. 05/2026 (File No. Policy-17/111/2022-CL-V-MCA) does is switch off the additional fee — the ₹100-per-day charge for late filing — for a defined set of forms, for FY 2025-26 only:

• Financial statements — up to 31 December 2026: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS).
• Annual returns — up to 31 January 2027: MGT-7 and MGT-7A.

The circular says the Ministry acted after receiving representations from stakeholders who were struggling to complete the annual filings — the same portal and form complaints the ICSI letter catalogued. If you want the form-by-form groundwork, our AOC-4 due date guide and MGT-7 annual return guide now carry dated update notes pointing here.

What the circular does not do

Three limits, and each one is a trap for somebody.

Your AGM deadline has not moved. Paragraph 3 says so in plain words: this circular shall not be read as extending the statutory time for holding AGMs. For a March year-end, that date was 30 September 2026 under Section 96. If your company missed it, you are in default today, and filing AOC-4 in December does not wash that away. The meeting default and the filing fee are separate problems running on separate tracks.

The normal fee is still payable. Only the additional fee is waived. A company that files AOC-4 on 20 December pays the same normal MCA fee it would have paid on 30 October — worked out on its authorised capital — and not a rupee of the daily charge. "Fee-free" in the headlines means late-fee-free. Budget accordingly.

The waiver covers seven forms, not the season. ADT-1, MGT-14, MSME Form I, DIR-12 — none of them is named in the circular, so none of them gets the shelter. Their clocks run exactly as before.

Think of it as a library running a late-fee amnesty. Your book was still due on the original date. The library has simply decided not to charge you if you bring it back this month. Return it after the amnesty ends, though, and the fine is worked out from the day the book was actually due — not from the day the amnesty closed. That is precisely how paragraph 4 of this circular behaves.

File after the window, and the meter restarts from day one

Paragraph 4 is the sentence most summaries skipped. Filings made after the window attracts all fees, including additional fees under the Companies (Registration Offices and Fees) Rules, 2014, counted from the date the filing was actually due. Not from 31 December. From the original due date.

Run the numbers on a company that held its AGM on 30 September. Its AOC-4 was due 30 October 2026. File on 15 December and the additional fee is ₹0 — inside the window. File on 15 January 2027 instead, and the count runs from 30 October: 77 days at ₹100 a day is ₹7,700 for that one form, on top of the normal fee. The amnesty does not give you a discount for the weeks it covered. It gives you a cliff edge.

MGT-7 works the same way, a month later: due 29 November 2026, sheltered till 31 January 2027, and counted from 29 November if you cross into February.

The trap: LLPs are not in this circular

If you run an LLP, close this headline and open your calendar. General Circular No. 05/2026 is a Companies Act measure. It names company forms. It says nothing about the LLP Act, because it cannot.

LLP Form 8 — the Statement of Account and Solvency — is still due on 30 October 2026. That is four days from now. There is no fee waiver, no extra month, nothing. I have already seen the confusion start: a partner reads "annual filing extended" on a news app and assumes his LLP is covered. It is not. Companies got the amnesty. LLPs did not.

Should you still file early?

My honest advice: yes, for most companies. The window is best used as insurance, not as a plan.

Your filed financials are a working document. Banks read them for limits and renewals. Investors and buyers read them in diligence. A company whose AOC-4 is still unfiled in January looks, from the outside, like a company with something stuck. There is also the practical side: MGT-7 builds on the filed financials, the January portal rush is entirely predictable, and an audit query that surfaces in December is much easier to answer than one that surfaces on 30 December.

Where the window genuinely helps is quality. If your audit is being rushed, your board report is being stitched together at midnight, or your XBRL tagging keeps failing validation — slow down and use the weeks. A wrong filing made on time is worse than a right filing made in November. That, I suspect, is what the MCA actually intended.

What to do this week

Four things. One: if your AGM was held on time and your audit is complete, file AOC-4 anyway and bank the clean record. Two: if the audit needs more time, tell your board the real position — fee shelter till 31 December for AOC-4 and 31 January for MGT-7, and a hard cliff after each. Three: check the forms the circular does not cover — ADT-1 and MSME Form I run on their own dates, with no shelter. Four: if there is an LLP anywhere in your group, Form 8 by 30 October. No exceptions, no amnesty.

And if you would rather the whole set — AOC-4, MGT-7 and the paper trail behind them — was simply handled for you, that is what our annual filing team does every filing season.

Annual filing extension: quick answers

Has the AOC-4 deadline been extended for FY 2025-26?

The statutory deadline has not changed — AOC-4 remains due within 30 days of your AGM under Section 137. What changed is the cost of being late: under General Circular No. 05/2026 you can file up to 31 December 2026 without additional fees. The normal filing fee still applies.

What is the last date for MGT-7 without a late fee?

31 January 2027, for MGT-7 and MGT-7A for FY 2025-26. File after that and additional fees are counted from the original due date — 29 November 2026 for a company that held its AGM on 30 September.

Is the AGM date extended too?

No. Paragraph 3 of the circular is explicit that statutory AGM timelines are untouched. A company that failed to hold its AGM on time remains liable under the Companies Act, separately from its filings.

Is LLP Form 8 covered by this extension?

No. The circular covers Companies Act annual forms only. LLP Form 8 remains due on 30 October 2026, with LLP late fees applying as usual.

Are ADT-1 and other annual forms covered?

No. The circular names only the AOC-4 family and MGT-7/MGT-7A. Every other form — ADT-1, MGT-14, MSME Form I, DIR-12 — keeps its own deadline and its own fee rules.

The extension the ICSI asked for has, in substance, arrived — the MCA just delivered it as a fee waiver rather than a deadline change. Used well, it is breathing room. Used as an excuse to stop, it is a ₹100-a-day lesson that starts counting from October.