The Ministry of Corporate Affairs (MCA) has entered the most critical compliance phase of FY 2024–25, with multiple statutory filings scheduled between October and November 2025. Following the migration to the MCA V3 portal and the technical instability that continues to affect filings, it is imperative for companies, LLPs, and professionals to understand the confirmed extensions, pending representations, and penalty implications to ensure seamless statutory compliance.
Statutory Filing Deadlines — October–November 2025
October 2025 Filings
| Form | Particulars | Statutory Due Date | Penalty for Default |
|---|---|---|---|
| DIR-3 KYC | KYC verification for all DIN holders as on 31 March 2025 | Extended to 31 Oct 2025 (Circular No. 05/2025 dated 15 Oct 2025) | ₹5,000 and DIN deactivation |
| ADT-1 | Auditor appointment within 15 days of AGM | 14 Oct 2025 (if AGM held 30 Sep 2025) | 12× standard filing fee |
| AOC-4 / AOC-4 XBRL / AOC-4 CFS | Filing of financial statements | 29–30 Oct 2025 | ₹100 per day; no upper limit |
| Form 8 (LLP) | Statement of Account & Solvency | 30 Oct 2025 | ₹100 per day |
| MGT-14 | Board resolutions for approval of accounts | Within 30 days of Board Meeting | ₹100 per day |
| MSME-1 | Half-yearly return (April–Sept 2025) | 31 Oct 2025 | Up to ₹3 lakh + imprisonment |
November 2025 Filings
| Form | Particulars | Statutory Due Date | Penalty for Default |
|---|---|---|---|
| MGT-7 / MGT-7A | Annual Return | 28–29 Nov 2025 | ₹100 per day; no upper limit |
| PAS-6 | Reconciliation of Share Capital Audit | 29 Nov 2025 | ₹100 per day |
Current Status of Extensions
Confirmed:
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DIR-3 KYC — Extended till 31 October 2025, without additional fee.
Representations Pending (ICSI submission dated 14 October 2025):
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Request to extend the due date for all annual forms — AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC, MGT-7, MGT-7A, ADT-1, DIR-12 — till 31 December 2025, without additional fees.
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General waiver sought for forms due between 1 September and 31 December 2025, citing widespread technical difficulties post-MCA V3 migration.
As of 16 October 2025, MCA has not issued any further relaxation beyond the DIR-3 KYC extension.
MCA V3 Migration — Continuing Technical Disruptions
The transition from MCA V2 to MCA V3 (implemented on 14 July 2025) continues to pose operational difficulties for stakeholders:
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Frequent portal downtime and login failures during peak load hours
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Validation errors and rejections due to altered form formats
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Mandatory upload of registered office photographs with GPS coordinates
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DSC authentication mismatches and system freezes
The portal was non-operational from 9–13 July 2025 during migration, without any fee waiver or automatic extension for forms due in that period.
Penalty Structure — Key Statutory Consequences
| Form | Default | Penalty / Consequence |
|---|---|---|
| AOC-4 (Financials) | Late filing | ₹100 per day, no cap |
| Non-filing | ₹50,000 + ₹100/day (max ₹5 lakh) | |
| MGT-7 (Annual Return) | Late filing | ₹100 per day, no cap |
| Non-filing | ₹50,000 per company/officer (max ₹5 lakh) | |
| DIR-3 KYC | Non-filing | ₹5,000 + DIN deactivation |
| ADT-1 / DPT-3 | Late filing | 12× normal filing fee |
| MSME-1 | Non-filing | Up to ₹3 lakh + imprisonment |
| Section 164(2) | Non-filing of AOC-4/MGT-7 for 3 years | Director disqualification for 5 years |
Possibility of Further Extensions
Based on current industry developments, a further extension is likely owing to:
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Persistent portal issues despite several rounds of technical updates.
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Formal ICSI representation with system log evidence.
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Precedent: CBDT extended the Tax Audit deadline to 31 October 2025.
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Festival and holiday season impacting audit and filing work.
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Past practice: MCA granted similar relaxations during earlier transitions (FY 2021–22, FY 2022–23).
However, until officially notified, professionals must assume original deadlines prevail and plan filings accordingly.
Professional Compliance Strategy
Immediate Priorities:
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File DIR-3 KYC by 31 October 2025 – confirmed extension.
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Prepare AOC-4 filings now; avoid reliance on speculative extension.
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Target MGT-7/MGT-7A completion by 28–29 November 2025.
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Monitor MCA Circulars daily through the official portal and professional bodies (ICSI, ICAI, ICMAI).
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Avoid last-day uploads — system congestion on V3 can cause repeated rejections.
Operational Best Practices:
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Keep registered office photographs with GPS details ready (mandatory in V3).
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Ensure DSC of signatory matches the director shown in the photograph.
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Conduct pre-validation of all e-forms before submission.
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Apply for AGM extension if required — subject to ROC discretion.
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File early to avoid the ₹100 per day penalty with no upper limit.
Concluding Note
As of mid-October 2025, the only confirmed relaxation from MCA is the extension of DIR-3 KYC till 31 October 2025. No relief has yet been notified for AOC-4 or MGT-7, despite strong professional representations and technical challenges.
Given the MCA V3 transition issues, companies and professionals must maintain proactive compliance discipline. Delayed filings can attract cumulative penalties and even director disqualification under Section 164(2).
Until further circulars are issued, the guiding principle remains clear —
“File on time, file early, and file right — compliance delayed is compliance denied.”
