As of October 16, 2025, the Ministry of Corporate Affairs (MCA) has not announced any extension for filing key annual compliance forms such as AOC-4, MGT-7, MGT-7A, or other ROC returns for Financial Year 2024–25. All statutory deadlines therefore continue to apply as per the Companies Act, 2013.
Current Due Dates for FY 2024–25 (No Extension Announced)
| Form | Particulars | Statutory Due Date | Example (AGM on Sept 30, 2025) |
|---|---|---|---|
| AOC-4 | Filing of Financial Statements | Within 30 days of AGM | October 29–30, 2025 |
| MGT-7 / MGT-7A | Filing of Annual Return | Within 60 days of AGM | November 28–29, 2025 |
| AOC-4 (OPC) | For One Person Companies | Within 180 days of financial year end | September 27, 2025 |
Companies are therefore advised to complete and submit their annual filings within these statutory timelines.
Only DIR-3 KYC Deadline Extended
The only extension currently granted by MCA pertains to DIR-3 KYC filings for directors.
| Particulars | Original Deadline | Extension Granted | Circular Reference |
|---|---|---|---|
| DIR-3 KYC / KYC-WEB | September 30, 2025 | Extended to October 31, 2025 without late fee | General Circular No. 05/2025 dated October 15, 2025 |
This relief applies only to director KYC filings and not to company annual returns like AOC-4 or MGT-7.
ICSI Representation Seeking Extension
The Institute of Company Secretaries of India (ICSI), in its latest representation dated October 14, 2025, has formally requested the MCA Secretary to extend the filing deadlines for annual forms up to December 31, 2025 without additional fees.
Key Points of the Representation:
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Forms Covered: AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), MGT-7, and MGT-7A.
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Extension Requested Till: December 31, 2025.
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Reasons Cited:
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Persistent technical glitches on the MCA-21 V3 portal.
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Pre-scrutiny errors, SRN rejection, and form validation failures.
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Ongoing challenges from V2 to V3 migration.
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Difficulty in meeting deadlines during the festive season.
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Additional Relief Sought: Waiver of additional fees for filings due between September 1 and December 31, 2025.
As of date, no official response or relaxation circular has been issued by the MCA on this request.
Historical Precedents of Extensions
MCA has, in previous years, provided similar relief in response to portal issues and stakeholder representations:
| Financial Year | Form | Extended Till | Circular Reference / Reason |
|---|---|---|---|
| 2020–21 | AOC-4 till Feb 15, 2022; MGT-7 till Mar 30, 2022 | General Circular No. 22/2021 | Pandemic-related delays |
| 2018–19 | AOC-4 till Nov 30, 2019; MGT-7 till Dec 31, 2019 | – | Festive and system issues |
| 2025 (V3 Migration) | 13 e-forms relaxation till Aug 15, 2025 | General Circular No. 01/2025 | Technical transition (V2→V3) |
Historically, such extensions have been announced in late October or early November, typically following professional body representations or widespread technical challenges.
Current Scenario and Likely Outcome
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No Official Extension Yet: Despite multiple ICSI representations and acknowledged portal difficulties, MCA has not issued any new circular extending AOC-4 or MGT-7 deadlines.
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Possibility of Extension: Based on precedent, a short extension (up to December 2025) remains reasonably possible, especially as the AOC-4 deadline (October 29–30) approaches.
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Comparable Relief: The CBDT recently extended the tax audit report deadline to October 31, 2025, citing similar portal issues, which may influence MCA’s decision.
Recommendation
Until an official relaxation is announced, companies and professionals should proceed as per the statutory deadlines:
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File AOC-4 by October 29–30, 2025 (or within 30 days of AGM).
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File MGT-7/MGT-7A by November 28–29, 2025 (or within 60 days of AGM).
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Continuously monitor the MCA website and General Circulars section for any last-minute updates.
Penalties for Non-Compliance
| Form | Delay Consequence |
|---|---|
| AOC-4 | ₹100 per day of delay (no upper limit) + penalties under Section 137(3) of the Companies Act. |
| MGT-7 / MGT-7A | ₹100 per day of delay (no upper limit). |
| Company Officers / Directors | Penalty up to ₹1 lakh plus ₹5,000 per day (maximum ₹5 lakh). |
Conclusion
As of October 16, 2025, no extension has been announced by the MCA for filing AOC-4 or MGT-7 for FY 2024–25.
While professional bodies have sought relaxation citing persistent MCA-21 V3 technical issues, companies must adhere to the statutory filing timelines unless an official circular grants relief.
Given past precedents and the current system challenges, an extension remains possible but not assured. Prudence demands that corporates complete and file their annual returns well before the due date to avoid additional fees and penalties.
