By CA Surekha S Ahuja
Statutory filing of audited financial statements in XBRL format
(April 1, 2024 – March 31, 2025)
Introduction – Why Form AOC-4 XBRL for FY 2024-25 Is a High-Risk Compliance Area
If you are a company, director, CFO, auditor, or compliance professional, Form AOC-4 XBRL for FY 2024-25 is no longer a routine ROC filing. With MCA tightening digital governance, introducing mandatory signed PDF attachments, and fixing professional accountability through GSR 371(E), XBRL filings have become a high‑exposure compliance event.
Thousands of companies commit avoidable errors every year due to incorrect applicability assessment, outdated taxonomy use, mismatches between XBRL and signed financials, or missed timelines—leading to heavy additional fees, penalties under Section 137, and even prosecution risk.
This authoritative guidance note is written to answer, in one place, the exact questions professionals search for:
Who is required to file AOC-4 XBRL for FY 2024-25?
What are the due dates, extensions, fees, and penalties?
Which attachments are now mandatory post‑July 2025?
How to file correctly on MCA V3 without rejection or resubmission.
Unlike generic blogs, this guide is law-backed, MCA-notification aligned, and practitioner-tested, making it suitable for reliance by companies and professionals alike.
Statutory Architecture (Law That Governs)
Section 137, Companies Act, 2013 – Obligation to file financial statements with ROC.
Companies (Filing of Documents and Forms in XBRL) Rules, 2015 (as amended) – XBRL mandate.
Schedule III (Division I/II/III) – Financial statement formats.
Companies (Indian Accounting Standards) Rules, 2015 – Ind AS companies.
GSR 371(E) dated 06.06.2025 – Mandatory authenticated PDFs and professional certification.
MCA V3 Portal – Exclusive filing platform.
Position in law: AOC‑4 XBRL is no longer a technical upload; it is a statutory declaration of financial truth with enhanced professional accountability.
What is Form AOC‑4 XBRL
Form AOC‑4 XBRL is the prescribed e‑form for filing audited financial statements in XBRL format with the Registrar of Companies for entities notified under the XBRL Rules.
It replaces normal AOC‑4 for eligible companies and applies to both standalone and consolidated financials.
Applicability – Who Must File AOC‑4 XBRL
A. Mandatory (Irrespective of Size)
All listed companies (NSE/BSE)
Indian subsidiaries of listed companies
Companies required to prepare Ind AS financial statements
Companies that have filed AOC‑4 XBRL in any earlier year
(Continuity rule: once XBRL, always XBRL, even if thresholds fall)
B. Unlisted Companies – Threshold Test
Based on latest audited financial statements, an unlisted company must file AOC‑4 XBRL if any one condition is met:
| Criterion | Threshold |
|---|---|
| Paid‑up share capital | ≥ ₹5 crore |
| Turnover | ≥ ₹100 crore |
C. Sector‑Specific Clarification
| Entity Type | Filing Mode |
| NBFCs | AOC‑4 (Non‑XBRL) |
| Banks | Non‑XBRL |
| Insurance Companies | Non‑XBRL |
| Housing Finance Companies | Non‑XBRL |
| Listed NBFC / Bank / Insurer | AOC‑4 XBRL mandatory |
Explicit Exemptions from XBRL
The following entities are outside XBRL applicability:
Small Companies (Paid‑up capital < ₹50 lakh and turnover < ₹2 crore)
One Person Companies (OPC)
Dormant Companies (Section 455)
Companies under strike‑off process
Section 8 companies (unless listed or Ind AS applicable)
Due Dates – FY 2024‑25 (Critical Update)
AGM Timeline
| Event | Due Date |
| AGM | On or before 30 September 2025 |
| Extended AGM | Up to 31 October 2025 (via approval / GNL‑1) |
AOC‑4 XBRL Filing Due Date
| Scenario | Due Date |
| Normal rule | Within 30 days of AGM |
| AGM on 30 Sept | 30 October 2025 |
| AGM on 31 Oct | 30 November 2025 |
| MCA extension (FY 2024‑25) | 31 December 2025 |
Government Fees & Additional Fees
Normal Filing Fees
| Authorised Capital | Fee |
| Up to ₹1 lakh | ₹200 |
| ₹1–10 lakh | ₹300 |
| Above ₹10 lakh | ₹600 |
Additional (Late) Fees
₹100 per day of delay
No maximum cap (post‑2018 amendment)
Penalties & Legal Consequences (Section 137)
| Nature of Default | Consequence |
| Company & officers | ₹10,000 + ₹100/day |
| Serious default | ₹50,000 – ₹3,00,000 |
| Extreme cases | Imprisonment up to 6 months |
| Remedy | Compounding under Section 441 |
Mandatory Attachments (Post‑14 July 2025 – Non‑Negotiable)
A. XBRL Instance Documents (Mandatory)
Standalone XBRL (.xml)
Consolidated XBRL (.xml), where applicable
Generated using MCA Taxonomy 2024
Validated through MCA Validation Tool (zero errors)
B. Mandatory Authenticated PDFs – GSR 371(E)
For filings on or after 14 July 2025, the following digitally signed PDFs are compulsory:
Balance Sheet
Statement of Profit & Loss
Cash Flow Statement
Notes to Accounts
Auditor’s Report
Board’s Report (Section 134)
PDFs must be digitally signed and marked as “authenticated copies”.
C. Conditional / Optional Attachments
| Document | When Required |
| AOC‑1 | Subsidiaries / JVs |
| CSR‑2 | CSR‑applicable companies |
| INC‑28 | Revision u/s 130 / 131 |
| Prior AOC‑4 SRN | Revised filing |
| Board Resolution | Best practice |
File size limits:
Total attachments ≤ 20 MB
Each non‑XML file ≤ 10 MB
Step‑by‑Step Filing Process (Practitioner‑Ready)
Confirm applicability (listing, thresholds, Ind AS, past XBRL).
Complete statutory audit (CARO 2024 where applicable).
Board approval of financials (date ≥ 31‑03‑2025).
Create XBRL using MCA Taxonomy 2024; map Schedule III / Ind AS accurately.
Validate XML using MCA Validation Tool (no errors).
Login to MCA V3 → MCA Services → Company e‑Filing → AOC‑4 XBRL.
Enter CIN, FY, AGM date, financial type, SRN nature.
Affix DSC of authorised signatory (Director / CEO / CFO / Manager).
Professional certification by CA / CS / Cost Accountant confirming XBRL–PDF parity.
Pre‑scrutiny → Pay fees → Generate SRN → Download acknowledgement.
Key Field‑Level Instructions
Financial year: 01‑04‑2024 to 31‑03‑2025
Select correct Schedule III Division or Ind AS
CSR disclosures must reconcile with CSR‑2
Government companies: disclose CAG comments
Revised filings require INC‑28 + order SRN + prior AOC‑4 SRN
Major MCA Updates – FY 2024‑25
GSR 371(E): Mandatory signed PDFs + professional certification
MCA V3 only – no V2 fallback
CSR‑2 integration
Updated taxonomy aligned with Schedule III & Ind AS
Extended filing deadline to 31 December 2025
Common Errors & Corrective Actions
| Error | Corrective Action |
| XBRL rejection | Re‑validate using latest taxonomy |
| PDFs not signed | Digitally sign before attachment |
| Size exceeds limit | Compress / split attachments |
| DSC mismatch | Use authorised signatory only |
| Certification missing | Upload professional certificate |
| Wrong FY | Use correct date range |
| Prior SRN pending | Close earlier filing first |
Pre‑Filing Compliance Checklist
CIN active; no strike‑off / name change pending
Class‑3 DSC valid for signatory
Audit & Board approval completed
XBRL validated (zero errors)
PDFs digitally signed & identical to XBRL
No pending prosecution under Section 137
Conclusion – The New Compliance Reality of AOC-4 XBRL
Form AOC-4 XBRL for FY 2024-25 represents a decisive shift in MCA’s compliance philosophy—from form-based disclosure to data integrity, traceability, and professional accountability.
Post 14 July 2025, XBRL filings are legally incomplete unless digitally signed financial statements, Board’s Report, and Auditor’s Report are attached and certified to be identical to the XBRL instance. Any mismatch now exposes companies, directors, CFOs, and certifying professionals to direct statutory consequences under Section 137.
For companies, this means AOC-4 XBRL must be treated as a board-level compliance item, not a clerical task. For professionals, it is a high-liability certification assignment demanding strict controls, validation discipline, and documentation integrity.
This guide is designed to function as a single-source compliance reference—covering applicability, exemptions, timelines, penalties, attachments, filing mechanics, and error resolution—so that your AOC-4 XBRL filing withstands ROC scrutiny, audit review, and future regulatory verification.
