If you run a private company, an OPC, or a small company, the answer is simple: you file MGT-7 filing every year under Section 92 of the Companies Act, 2013 — unless you are a One Person Company or a small company, in which case you file the abridged MGT-7A. Same deadline. Same Rs.100-per-day penalty. Different form, depending on your company's size.

That is the whole game. Now let me explain why it matters, because choosing the wrong form is one of the most common errors I see in ROC filings.

What Is MGT-7 Filing and Who Has to Do It?

MGT-7 is the annual return prescribed under Section 92(1) of the Companies Act, 2013. Every company registered in India — private, public, listed, unlisted — must file it each financial year. It is a snapshot of your company as on the date of the AGM: shareholding pattern, directors and key managerial personnel, indebtedness (secured and unsecured loans), and the number of board and general meetings held during the year.

The deadline is fixed by law: within 60 days of the Annual General Meeting. For a company whose financial year ends on March 31, the AGM must be held by September 30 — which makes the MGT-7 due date November 29. Miss it, and Section 403 hits you with an additional fee of Rs.100 for every single day of delay. It compounds quietly. I have seen directors wince when the challan shows a figure they did not expect.

The form must be signed by a director and the company secretary, or by the director alone where the company has no whole-time company secretary. For prescribed classes of companies — listed companies, and unlisted companies with paid-up capital of Rs.10 crore or more, or turnover of Rs.50 crore or more — the annual return must also be certified by a practising company secretary.

If annual ROC work feels like a treadmill, our ROC annual filing service handles the full cycle — AOC-4, MGT-7 and ADT-1 — so the three filings never drift apart.

What Is MGT-7A and How Is It Different?

MGT-7A is the abridged annual return, introduced in 2021 through the Companies (Management and Administration) Amendment Rules. It is available only to two categories: One Person Companies (OPCs) and small companies.

A small company, as defined in Section 2(85), is one where paid-up share capital does not exceed Rs.4 crore and turnover does not exceed Rs.40 crore in the immediately preceding financial year — provided it is not a holding or subsidiary company, a Section 8 company, or governed by a special Act. An OPC gets a similar relaxation. The regulator's logic is plain: a two-member company should not be doing the same paperwork as a listed giant.

MGT-7A covers the same core information — shareholding, directors, indebtedness, meetings — but with fewer schedules and lighter disclosure requirements. The deadline is identical: 60 days from the AGM, i.e. November 29 for a September 30 AGM. The penalty is identical too: Rs.100 per day under Section 403. The abridgment is in the form, not in the consequences of skipping it.

Which One Applies to Your Company?

Here is the part where I have seen people go wrong, and where a real-world analogy helps. Think of it like the queues at an airport security check. There is a general queue and an express queue for small handbags. You do not get to pick the express lane just because you are in a hurry — you pick it because your baggage qualifies. If you walk into the wrong lane, you are sent back to start. The MCA works the same way: file MGT-7A when your company does not qualify as an OPC or small company, and the filing will not survive scrutiny.

So work it through in this order:

First, are you an OPC? Then MGT-7A. Remember, an OPC need not hold an AGM at all — Section 96(1) exempts it. In that case, the annual return is due within 60 days of the financial year-end, i.e. by May 30, not November 29. This is the detail most OPC directors miss.

Second, do you meet both small-company thresholds — capital of Rs.4 crore or less AND turnover of Rs.40 crore or less — with none of the exclusions? Then MGT-7A.

Third, everyone else — every other private company, every public company, every listed company — files the full MGT-7. If your company crossed the small-company limits this year, you move back to MGT-7 for this year. The qualification is tested fresh each financial year.

Common Mistakes I See Every Filing Season

The first is the OPC trap I mentioned above: OPC directors assuming the November 29 deadline applies to them. It does not. An OPC's MGT-7A is due by May 30, counted from the financial year-end, since no AGM is held.

The second is filing MGT-7A based on last year's status. Small-company qualification is reassessed every year. A company that crossed Rs.40 crore in turnover this March cannot file the abridged form this season.

The third is treating MGT-7 filing as the only annual ROC event. It is not. AOC-4 — the financial statements filing — is due within 30 days of the AGM, and ADT-1 — the auditor appointment form — has its own deadline. A clean MGT-7 means little if your AOC-4 filing is late and attracting its own Rs.100-per-day additional fee.

The fourth is signature errors: an unsigned form, a form signed by a director who resigned mid-year, or a missed CS certification where one is mandatory. The portal accepts the upload; the ROC notices the defect later.

What If You Already Missed the Due Date?

File anyway, immediately. There is no provision to waive the additional fee — Rs.100 per day runs from the day after the due date until the filing date. The fee is charged per form, so a company late on both AOC-4 and MGT-7 pays the daily fee twice over. Directors also face their own penalty under Section 92(5): a minimum of Rs.50,000 extending up to Rs.5,00,000, and officers in default face similar exposure. The math always favours filing today over filing next week.

One more thing worth knowing: the annual return, once filed, becomes a public document. Lenders, investors and counterparties read it. A clean, on-time filing history quietly tells everyone that the company is well-run. A gap-ridden one does the opposite.

The Bottom Line

MGT-7 is the default annual return under Section 92. MGT-7A is the abridged version reserved for OPCs and small companies. Same 60-day deadline, same Rs.100-per-day penalty, same public-record status. Work out your company's qualification each year, file the right form, and get the signatures right. If you want the full annual compliance — MGT-7, AOC-4 and ADT-1 filing — handled as one job by people who do this daily, our MGT-7 filing service is built exactly for that.