Saturday, September 27, 2025

Filing AOC-4 in MCA V3: Financials, Comparatives & New Disclosures

By CA Surekha

AOC-4 is one of the most critical MCA filings, and while MCA V3 has automated large parts of it, the financial statements and their disclosures still need careful handling. 

The filing of Form AOC-4 (filing of financial statements and other documents with ROC) is a statutory compliance under Section 137 of the Companies Act, 2013. With the MCA V3 Portal, much of the process has been automated through intelligent pre-filling and linked filing. But accuracy, regrouping of financials, and disclosure compliance still require careful attention.

This note provides a complete A-to-Z guide for filing AOC-4 under MCA V3, covering what’s prefilled, what needs manual input, procedural steps, new disclosure requirements, and best practices.

Prefilled Data in AOC-4 under MCA V3

The system reduces duplication by automatically fetching information already available on MCA records. Prefilled fields include:

  • Company Master Data

    • Company Name & CIN

    • Date of Incorporation & ROC Jurisdiction

    • Registered Office Address (as on FY-end & current date)

    • Company Category, Sub-category, and Class

    • Authorized & Paid-up Capital

  • Director Details

    • DIN, names, and status from DIR-11/DIR-12 filings

    • Current directors synced with MGT-7

  • Shareholding & Capital Structure

    • Shareholding pattern carried forward from previous MGT-7

    • Capital changes auto-updated from PAS-3 / SH-7

  • Financial Data (Comparative Figures)

    • Previous year Balance Sheet & P&L account from last filed AOC-4

    • Ratios calculated by system

Note: Prefilled figures are taken “as filed” in the previous year — regrouping/reclassification is not automated.

Manual Data Entry Required

While 80% of data is prefilled, these must be entered/verified manually:

  • Financial Statements for Current Year

    • Balance Sheet line items

    • Profit & Loss statement

    • Notes to accounts

  • Comparative Figures (Previous Year)

    • Adjust if regrouped/reclassified

    • Provide justification in “Notes/Explanation”

  • New Disclosure Requirements

    1. CSR Disclosures (if applicable)

      • Prescribed spend vs. actual

      • Unspent amounts (ongoing projects, transfer to fund)

      • Details of projects

      • Auto-linked with CSR-2

    2. POSH Compliance

      • Constitution of ICC

      • Number of complaints received/disposed

    3. Gender-wise Employee Count (as at March 31)

    4. Maternity Act Compliance Statement

    5. Audit Trail Requirement (w.e.f. 01.04.2023)

      • Confirmation that accounting software used has audit trail enabled

    6. Schedule III Disclosures

      • Ageing of trade receivables/payables

      • Capital Work-in-Progress ageing

      • Loans & advances to promoters, directors, KMPs

      • Details of undisclosed income (if any)

      • Crypto/digital assets holdings/transactions

  • Other Specific Details

    • Meeting dates & director attendance (synced with MGT-7 but requires manual confirmation)

    • Explanations for any financial variances

Handling Previous Year Figures: Grouping & Regrouping

This is a critical compliance point.

  • What MCA V3 Does:

    • Auto-fills last year’s figures exactly as filed in previous AOC-4.

  • Your Responsibility:

    • Align last year’s figures with the current year presentation (as per Schedule III).

    • Regroup/reclassify if necessary.

    • Insert a standard note: “Previous year figures have been regrouped/reclassified wherever necessary to conform with current year presentation.”

Mismatch between audited financials & AOC-4 filing is a common ground for ROC scrutiny — avoid by carefully validating.

Step-by-Step Procedural Guide for AOC-4 Filing in MCA V3

Phase 1: Login & Setup

  1. Login as Business User → DIN/PAN validation auto-links your companies.

  2. Navigate to “Company E-filing” → Portal auto-suggests AOC-4 based on due dates.

Phase 2: Prefill & Verification

  1. System loads prefilled master data, director details, and comparative figures.

  2. Verify registered office, capital structure, and director details.

Phase 3: Financial Data Entry

  1. Enter current year Balance Sheet & P&L items.

  2. Validate prefilled previous year comparatives → regroup if required.

  3. Add financial ratios (auto-calculated but editable if needed).

Phase 4: Mandatory Disclosures

  1. Fill CSR details (auto-linked with CSR-2, but cross-check).

  2. Enter POSH, gender-wise employees, and maternity compliance.

  3. Fill Schedule III disclosures (ageing schedules, loans, crypto, etc.).

  4. Confirm audit trail compliance.

Phase 5: Linked Filing Sync

  1. Sync with MGT-7 → director/meeting/shareholder info flows.

  2. System ensures consistency across AOC-4, CSR-2, and related forms.

Phase 6: Validation & DSC Signing

  1. Generate pre-submission error summary.

  2. Correct errors → revalidate.

  3. Sign digitally (DSC auto-detects roles).

  4. File & make single payment for linked forms.

Common Pitfalls to Avoid

❌ Filing AOC-4 before updating MGT-7 (causes mismatch)
❌ Ignoring regrouping of previous year figures
❌ Rounding off to lakhs/crores instead of absolute rupees
❌ Missing POSH/CSR disclosures (new requirement)
❌ Not documenting justifications for changes in prefilled data

Best Practices for Error-Free AOC-4

✔️ Start with MGT-7 → let its data flow into AOC-4
✔️ Cross-check with audited financials (same grouping/presentation)
✔️ Use “Save Draft” frequently to avoid portal crashes
✔️ Break large Excel uploads into smaller parts for validation
✔️ Keep office photos, CSR records, and Board’s Report ready before filing

Compliance Timeline

  • 30 days from AGM (for companies holding AGM)

  • 30 days from Board approval (if AGM not required, e.g., OPCs)

  • Filing Fees: Based on company’s authorized share capital; additional fees apply for delay

Common Red Flags

⚠️ Previous year regrouping not explained → may trigger resubmission.
⚠️ CSR disclosure missed even if “Not Applicable”.
⚠️ Auditor details mismatch with ADT-1 filed earlier.
⚠️ Shareholding % mismatch with annual return.
⚠️ Financial statements not digitally signed in PDF.

The MCA V3 Portal makes AOC-4 filing 80% automated by pre-filling company data and previous year financials. But the remaining 20%—manual disclosures, regrouping, and validations—require professional judgment.

By following the mantra:

“Review, Don’t Recreate”

you can turn AOC-4 from a stressful compliance burden into a simple verification exercise, ensuring speed, accuracy, and full legal compliance.



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