Incorporation is the start of compliance, not the end of it
The certificate of incorporation feels like the finish line. It is actually the starting gun. From the day a Private Limited company exists, it owes the Registrar of Companies (ROC) a fixed rhythm of filings every year — some tied to the financial year, some to the date of the annual general meeting, some that fall due on the same calendar date regardless of whether the company did any business at all. Miss them and the penalties are not a slap on the wrist: the daily fine for a late annual return has no upper cap, a missed director KYC deactivates the director's DIN, and a company that ignores its filings long enough can be struck off the register. This is the full annual compliance calendar for a Private Limited company, laid out by when each filing is actually due.
The one-time filings in the first year
A newly incorporated company has three obligations that do not repeat, and getting them wrong in year one is the most common — and most expensive — mistake founders make.
- First auditor: the Board must appoint the company's first statutory auditor within 30 days of incorporation. The auditor then holds office until the conclusion of the first AGM.
- INC-20A — declaration of commencement of business: under Section 10A of the Companies Act, 2013, a company with share capital must file INC-20A within 180 days of incorporation, declaring that every subscriber has paid the value of the shares they agreed to take. Until it is filed, the company cannot legally commence business or borrow money. The penalty for missing it is steep — ₹50,000 on the company and ₹1,000 per day on every officer in default, up to ₹1 lakh — and the ROC can move to strike the company off.
- First AGM: the first annual general meeting must be held within nine months of the end of the first financial year (every AGM after that gets six months). So a company incorporated in, say, August 2025 whose first financial year ends 31 March 2026 must hold its first AGM by 31 December 2026.
The annual calendar, by due date
For a company whose financial year ends on 31 March, the recurring filings fall in this order. The dates below assume the AGM is held on the last permitted day (30 September); if you hold the AGM earlier, the AOC-4 and MGT-7 clocks start earlier too.
- 30 June — DPT-3 (return of deposits). An annual return of deposits and of money that is not treated as a deposit — which includes loans a company has taken from its directors. Even a company that has only borrowed from its own founders has to file it. Due by 30 June for the year ended 31 March.
- 30 September — DIR-3 KYC. Every person who holds a Director Identification Number (DIN) as on 31 March must complete their KYC with the MCA by 30 September. Miss it and the DIN is deactivated; reactivating it costs a flat ₹5,000 late fee.
- 30 September — Annual General Meeting. The AGM itself must be held within six months of the financial-year end, so by 30 September for a 31 March year-end. The AGM is where the accounts are adopted and the auditor is appointed or ratified — which is why the two big filings below hang off its date.
- Within 15 days of the AGM — ADT-1 (auditor appointment). When an auditor is appointed at the AGM, ADT-1 records it with the ROC within 15 days.
- 31 October — MSME-1 (first half). A half-yearly return of any amounts outstanding for more than 45 days to suppliers registered as micro or small enterprises. The return for April–September is due by 31 October; the October–March return is due by 30 April.
- Within 30 days of the AGM — AOC-4 (financial statements). The audited balance sheet, profit and loss account and the associated reports are filed in AOC-4 within 30 days of the AGM — so roughly 30 October if the AGM was on 30 September.
- Within 60 days of the AGM — MGT-7 / MGT-7A (annual return). The company's annual return — its shareholding, directors and changes over the year — is filed within 60 days of the AGM, roughly 29 November. Small companies and One Person Companies file the shorter MGT-7A instead of MGT-7.
The obligations that are not a single filing
Some of the calendar is not a form with a deadline but a discipline the company has to keep all year:
- Board meetings: a Private Limited company must hold a minimum of four board meetings a year, with no more than 120 days between two consecutive meetings. Small companies and OPCs get a relaxation — at least one meeting in each half of the calendar year, with a gap of not less than 90 days.
- Statutory registers and minutes: registers of members, directors and charges, and minute books for board and general meetings, have to be maintained and kept current. They are the first thing a diligence review or an investor's lawyer asks for.
- The income-tax return: separate from the ROC filings and filed with the Income Tax Department, not the MCA. A company that is subject to audit files its return by 31 October; the tax audit report itself is due earlier. The company also runs monthly and quarterly TDS and, where registered, GST obligations through the year.
What it actually costs to miss these
The penalties are what make this calendar matter. For the two annual filings — AOC-4 and MGT-7 — a late fee of ₹100 per day, per form, runs with no maximum cap, so a return forgotten for a year quietly becomes a five-figure liability. A missed DIR-3 KYC deactivates the director's DIN, which freezes that person out of signing anything until they pay the ₹5,000 to reactivate it. A missed INC-20A carries the ₹50,000-plus-₹1,000-a-day exposure described above and blocks the company from borrowing. And a company that simply stops filing its annual returns can, after enough defaults, be marked a defaulting company and eventually struck off, with its directors disqualified from other boards. None of this is discretionary once the deadline passes; the fee is automatic.
Where this sits in the founder journey
This calendar is the reason the choice of structure matters so much in the first place. A Private Limited company carries the heaviest compliance load of any Indian business form, which is exactly the trade-off we set out in our comparison of the five business structures — the compliance cost is the price of being fundable. An OPC carries almost the same calendar with a few relaxations. If you are still deciding whether to incorporate at all, start with our guide to starting a business in India; and if a funding round is on the horizon, the clean statutory record this calendar produces is precisely what survives the diligence we describe in the Startup India and DPIIT recognition guide.
How we handle it at RDA, Baner
At RDA Advisory, Baner, we run the compliance calendar so you never see a penalty notice. We take on the whole cycle for our Private Limited and OPC clients — the first-year INC-20A and auditor appointment, the AGM and the AOC-4 and MGT-7 filings against its date, DPT-3, the two MSME-1 returns, DIR-3 KYC for every director, and the board meetings, minutes and statutory registers that have to be kept through the year. You get a dated calendar at the start of the year and a reminder before each filing, not a scramble in September. Office No. 102, Snehraj Apartment, Baner, Pune 411045 · call +91 77570 45059.
Just incorporated? Get the calendar set up before the first deadline
Registered a company in Pune and not sure what you now owe the ROC? RDA maps your exact due dates from your incorporation date and financial year, files the first-year forms, and takes over the annual cycle so nothing lapses. Book a consult at rdatax.in or call +91 77570 45059 — RDA Advisory, Baner, Pune. If you are choosing between structures first, read our business-structure comparison to see why the company form carries this calendar.
Verification note: The filing obligations and time limits stated here are based on the Companies Act, 2013 and the rules made under it, as administered by the Ministry of Corporate Affairs (mca.gov.in): the declaration of commencement of business in Form INC-20A within 180 days of incorporation under Section 10A, with the penalty of ₹50,000 on the company and ₹1,000 per day on officers in default up to ₹1 lakh; the appointment of the first auditor by the Board within 30 days of incorporation and the filing of Form ADT-1; the holding of the first AGM within nine months of the end of the first financial year and subsequent AGMs within six months of the financial-year end; the annual return of deposits in Form DPT-3 by 30 June; director KYC in Form DIR-3 KYC by 30 September, with DIN deactivation and a ₹5,000 reactivation fee on default; the half-yearly MSME Form I returns by 31 October and 30 April; the filing of financial statements in Form AOC-4 within 30 days of the AGM and of the annual return in Form MGT-7 (or MGT-7A for small companies and OPCs) within 60 days of the AGM, with a late fee of ₹100 per day per form and no maximum cap; and the requirement to hold a minimum of four board meetings a year with a gap of not more than 120 days (relaxed for small companies and OPCs). Due dates assume a financial year ending 31 March and an AGM held on the last permitted date; the AOC-4 and MGT-7 deadlines move with the actual AGM date. Filing dates, fees and forms are periodically revised by the MCA, and the MCA has in the past granted extensions for specific forms; confirm the current position for your company with your CA or company secretary. This is general information, not legal or professional advice.
