Nidhi Company Annual Filing: NDH-1, NDH-3, NDH-4 Deadlines

A Nidhi company files NDH-3 twice a year (due 30 October and 30 April), NDH-1 within 90 days of the financial year end (29 June for a March year-end), and the standard AOC-4 and MGT-7 like any company. Through the year it must maintain 200 members, net owned funds of at least ₹10 lakh, a 1:20 net-owned-funds-to-deposits ratio, and 10% of deposits as unencumbered term deposits.

A Nidhi company is not like other companies, and its filings should not be treated like other companies' filings. Your depositors are your members. Your borrowers are your members. When compliance slips in a Nidhi, it is not an abstract regulatory problem — it is your neighbours' savings sitting in a company whose paperwork says one thing and whose books say another.

The regulator understands this. That is why Nidhi companies carry extra filings on top of the standard ones. Here is the full set for FY 2025-26, in plain terms.

What is NDH-3, and when is it due?

NDH-3 is the Nidhi company's half-yearly return to the ROC, reporting deposits, loans, membership and net owned funds as of 30 September and 31 March. This is the filing that keeps the regulator's eye on your deposit book through the year. NDH-3 is filed twice — for the half year ending 30 September (due by 30 October) and the half year ending 31 March (due by 30 April). It reports your deposits, loans, membership numbers, and net owned funds as of that date.

Think of it as a health check-up the doctor insists on twice a year. The numbers in your NDH-3 should tell the same story as your books. If deposits have grown faster than your net owned funds, the ratio will show it — and the permitted ratio of net owned funds to deposits is 1:20. Cross it, and you have a compliance event on your hands, not just a number on a form.

What does NDH-1 confirm?

Due within 90 days of the financial year end — 29 June for a March year-end. NDH-1 is a compliance certificate of sorts: it confirms that your company met the Nidhi Rules through the year. Did you keep unencumbered term deposits of at least 10% of outstanding deposits? Did lending stay within the member-only, prescribed-limit boundaries? NDH-1 is where you put that on record.

This is the filing where shortcuts surface. If the 10% unencumbered deposit requirement was breached even briefly during the year, the honest course is to disclose and rectify — the regulator's view of a disclosed lapse is very different from its view of a hidden one.

What is NDH-4 for?

A company that wants to be recognised as a Nidhi files NDH-4 within 60 days of incorporation, applying for the declaration. Existing companies that never completed this step sometimes discover — usually during a bank's KYC review or a member dispute — that their Nidhi status was never formally declared. If that is your situation, regularise it before a dispute forces the issue.

And the thresholds that come with Nidhi status are not suggestions: 200 members within one year of incorporation, minimum net owned funds of ₹10 lakh, and the 1:20 ratio mentioned above. These are the conditions on which the entire Nidhi framework rests.

Do Nidhi companies still file AOC-4 and MGT-7?

Being a Nidhi does not exempt you from the Companies Act calendar. AOC-4 (financial statements) within 30 days of the AGM, MGT-7 (annual return) within 60 days — the same ₹100-per-day additional fee applies for delay. For a 30 September 2026 AGM, that means 29 October and 29 November 2026 respectively.

The 10% unencumbered deposit rule, made concrete

The unencumbered term deposit requirement confuses people until you put numbers on it. Suppose your Nidhi holds ₹5 crore in member deposits. You must keep at least ₹50 lakh in term deposits with a scheduled commercial bank — unencumbered, meaning not pledged as security for any loan, not earmarked for anything else. It is the members' emergency buffer, sitting where nobody can touch it.

"Unencumbered" is the word managements trip over. A deposit that secures the company's own overdraft is not unencumbered. A deposit held at a co-operative bank that is not a scheduled commercial bank does not count. When the NDH-1 asks you to confirm this, it is asking about the actual position through the year — not the position on the one day you remembered to check.

Why members should care — and why you should tell them

Here is the part most Nidhi managements miss. Your members chose a Nidhi because they trust it more than an impersonal institution. That trust is your real capital. Filing on time, keeping the ratios clean, and being able to show a member the filed NDH-3 when asked — these are not administrative chores. They are the visible proof that the trust is well placed.

A Nidhi that files late, misses its half-yearly return, or lets its member count drift below 200 is sending a message to every depositor, whether it means to or not. Make sure the message your filings send is the right one.

If your Nidhi's filing calendar has gaps — a missed NDH-3, an undeclared status, ratios drifting close to the line — talk to a professional who works with Nidhi companies specifically. Member money deserves specialist attention, not generalist guesswork.

Frequently asked questions

What is the difference between NDH-1 and NDH-3?

NDH-3 is the half-yearly numbers return — deposits, loans, members and net owned funds, filed twice a year. NDH-1 is the annual compliance certificate, due within 90 days of the year end, confirming you met the Nidhi Rules through the year. One reports the figures; the other certifies the conduct.

What happens if our member count falls below 200?

You are in breach of a core Nidhi condition. The 200-member requirement must be met within one year of incorporation and maintained after that. A sustained shortfall puts your Nidhi status at risk — rebuild membership deliberately and document the effort rather than waiting for the regulator to notice.

Can our deposits exceed twenty times our net owned funds?

No. The 1:20 ratio of net owned funds to deposits is a hard boundary, not a guideline. If deposit growth is outpacing owned funds, you must either raise owned funds or slow deposit acceptance. The NDH-3 will show the ratio either way.

What exactly counts as an "unencumbered" deposit?

A term deposit with a scheduled commercial bank that is not pledged, earmarked, or otherwise committed — freely available as the members' buffer. A deposit securing your own overdraft, or one held at a non-scheduled bank, does not count toward the 10%.

We have run as a Nidhi for years but never filed NDH-4. Does it matter?

Yes. NDH-4 is the formal declaration of Nidhi status, due within 60 days of incorporation, and banks and disputing members do check. If it was never filed, regularise it now — a missing declaration discovered during a dispute is far harder to explain than one you fixed yourself.