By CA Surekha Ahuja
Column-by-Column Reporting - CC, OD & Term Loans - Reconciliation Framework - Compliance Risks - All FAQs Resolved
Filing Deadline Alert
Due Date: 30 June 2026
| Particulars | Exposure |
|---|---|
| Base Penalty for Late Filing | ₹5,000 |
| Continuing Default | ₹500 per day |
| Serious Deposit Violations under Section 73 | Penalty up to ₹1 Crore or 2× Deposit Amount (subject to statutory limits) and other consequences under the Companies Act |
Important: DPT-3 for FY 2025–26 should be filed on or before 30 June 2026. Delayed filing may attract additional fees and continuing default consequences under the Companies Act, 2013.
Introduction & Legal Framework
Form DPT-3 is prescribed under Rule 16 and Rule 16A of the Companies (Acceptance of Deposits) Rules, 2014, read with Sections 73 to 76 of the Companies Act, 2013.
The form is used for reporting:
- Deposits accepted by a company; and/or
- Outstanding receipts of money not treated as deposits under Rule 2(1)(c).
Every company other than a Government company should evaluate its reporting obligation under Rule 16 and Rule 16A as on 31 March. In practice, companies having outstanding deposits and/or receipts of money falling within the reporting framework of the Deposit Rules generally require DPT-3 compliance.
For most private limited companies, DPT-3 primarily involves reporting:
- Director loans
- Bank borrowings
- Cash Credit (CC) facilities
- Overdraft (OD) facilities
- Working capital borrowings
- Inter-corporate borrowings
- Share application money
- Customer advances
- Other exempted receipts
Why DPT-3 Matters
Most DPT-3 errors arise not because of complex law but because of:
- Incorrect purpose selection
- Omission of bank borrowings
- Wrong classification of director loans
- Incorrect reporting of share application money
- Misclassification of customer advances
- Failure to reconcile figures with audited financial statements
A properly prepared DPT-3 should therefore be supported by legal analysis, reconciliation with books of account and verification of exemption conditions under Rule 2(1)(c).
Step 1 – Purpose Selection: The Most Critical Decision
Before entering any figures, select the correct purpose.
For most companies, this is the single most important decision in the entire filing process.
Practical Rule
For the vast majority of private limited companies, the appropriate selection is:
"Particulars of transactions not considered as deposit."
| Purpose Option | Select When | Columns to Fill | Auditor Certificate |
|---|---|---|---|
| Onetime Return | Historical outstanding amounts from 01.04.2014 to 31.03.2019 not considered deposits | Column 14 | Required |
| Particulars NOT considered as Deposit | Only exempted receipts such as director loans, bank loans, inter-corporate borrowings etc. | Column 15 | Generally Not Required |
| Return of Deposit + Particulars NOT Deposit | Both deposits and exempted receipts exist | Columns 10, 12, 13, 15 | Required |
| Return of Deposit | Company has reportable deposits | Columns 8(d), 9, 10, 11, 12, 13 | Required |
Step 2 – Column-by-Column Reference Guide
Basic Information (Columns 1–7)
| Column | Field | What to Enter | Important Note |
|---|---|---|---|
| 1(a) | CIN | Valid CIN | Mandatory |
| 2 | Company Details | Verify pre-filled details | Update email if required |
| 3 | Purpose | Select one option only | Determines active fields |
| 4 | Company Type | Public / Private | Verify carefully |
| 5 | Government Company | Yes / No | Refer Section 2(45) |
| 6 | Objects | Verify main objects | Check pre-filled data |
| 7(b) | Date of Last Closing | 31 March of relevant FY | Annual reporting date |
Financial Information (Columns 8–15)
| Column | Particulars | Requirement |
|---|---|---|
| 8 | Net Worth | Based on latest audited financial statements |
| 8(d) | Maximum Deposit Limit | Relevant mainly for eligible public companies |
| 9 | Number of Depositors | Applicable where deposits exist |
| 10 | Particulars of Deposits | Applicable for deposit reporting |
| 11 | Matured but Unclaimed Deposits | Mandatory where applicable |
| 12 | Liquid Assets | Applicable where deposits exist |
| 13 | Charge Details | Applicable where charge exists |
| 14 | Outstanding Amount Not Considered Deposits | One-time return only |
| 15 | Particulars Not Considered Deposits | Most important column for private companies |
Practical Formula Note – Net Worth
Net Worth = Paid-up Share Capital + Free Reserves + Securities Premium − Accumulated Losses − Deferred/Miscellaneous Expenditure − Unprovided Depreciation
Common Error: Including revaluation reserves in net worth.
Practical Formula Note – Maximum Deposit Limit
Maximum Deposit Limit = Net Worth × 35%
Applicable primarily to eligible public companies.
Step 3 – Column 15: Complete Exempted Deposit Breakdown
Column 15 is the most important disclosure section for private companies.
| Sub-Column | Nature of Transaction | Reportable | Example |
|---|---|---|---|
| 15(a) | Government / Statutory Authority Loans | Yes | SIDBI, State Government |
| 15(b) | Foreign Government / Institution Borrowings | Yes | ECB, Foreign Institution |
| 15(c) | Banking Facilities and Borrowings (including CC, OD, Working Capital and Term Loans) | Yes | CC, OD, Working Capital, Term Loan |
| 15(d) | Public Financial Institution Loans | Yes | IFCI, NABARD |
| 15(f) | Inter-Corporate Borrowings | Yes | Loan from another company |
| 15(g) | Share Application Money | Subject to conditions | Pending allotment |
| 15(h) | Director Loans | Yes | Director funding |
| 15(k) | Employee Security Deposit | Subject to conditions | Employee deposit |
| 15(m) | Business Advances | Subject to conditions | Customer advance |
| Relevant Clauses | Debentures, Convertible Notes, AIF Funding etc. | As applicable | Based on facts |
DPT-3 Reporting vs Non-Reporting Matrix
| Particulars | Reportable | Column |
|---|---|---|
| Bank CC | Yes | 15(c) |
| Bank OD | Yes | 15(c) |
| Bank Term Loan | Yes | 15(c) |
| Working Capital Facility | Yes | 15(c) |
| Director Loan | Yes | 15(h) |
| Inter-Corporate Loan | Yes | 15(f) |
| Share Application Money (within prescribed period) | Yes | 15(g) |
| Customer Advance (within exemption period) | Yes | 15(m) |
| Public Deposits | Yes | 10 |
| Trade Creditors | No | NA |
| MSME Creditors | No | NA |
| GST Payable | No | NA |
| TDS Payable | No | NA |
| PF / ESI Payable | No | NA |
| Salary Payable | No | NA |
| Directors' Remuneration Payable | No | NA |
| Audit Fee Provision | No | NA |
| Professional Fee Provision | No | NA |
| Outstanding Expense Provisions | No | NA |
| MTM Loss | No | NA |
| Government Grants | Generally No | NA |
Critical Exclusions
The following should generally not be disclosed under DPT-3:
- Trade creditors
- MSME creditors
- Directors' remuneration payable
- Salary payable
- Audit fee provisions
- Professional fee provisions
- Outstanding expense provisions
- Interest accrued but not due
- Fully repaid loans
- MTM losses
- Statutory dues
Step 4 – CC, OD & Term Loan Treatment
Bank borrowings are among the most frequently misreported items in DPT-3.
Decision Matrix
| Borrowing Type | Reportable | Column |
|---|---|---|
| Cash Credit (CC) | Yes | 15(c) |
| Overdraft (OD) | Yes | 15(c) |
| Working Capital Loan | Yes | 15(c) |
| Bank Term Loan | Yes | 15(c) |
| Director Loan | Yes | 15(h) |
| Inter-Corporate Loan | Yes | 15(f) |
Amount to be Reported
| Component | Include |
|---|---|
| Principal Outstanding | Yes |
| Interest Accrued and Due | Yes |
| Interest Accrued but Not Due | No |
| Fully Repaid Amounts | No |
Reporting Formula
Amount Reportable = Principal Outstanding as on 31 March + Interest Accrued and Due
Common Error: Reporting sanctioned limits instead of actual outstanding balances.
CC / OD Practical Note
CC and OD facilities are generally repayable on demand. Accordingly, the outstanding balance as on 31 March is ordinarily considered for reporting.
Director Loan Reporting
Verification Formula
Amount Reportable under Column 15(h) = Outstanding Director Loan as on 31 March + Interest Accrued and Due
Common Error: Reporting original loan amount instead of year-end outstanding balance.
Inter-Corporate Borrowings
Verification Formula
Amount Reportable under Column 15(f) = Outstanding ICD as on 31 March + Interest Accrued and Due
Share Application Money
| Position | Treatment |
|---|---|
| Within prescribed period | Column 15(g) |
| Beyond prescribed period | Review deposit implications |
Practical Verification Note
Every old share application money balance should be separately reviewed before claiming exemption.
Customer Advances
| Position | Treatment |
|---|---|
| Within exemption conditions | Eligible for exemption |
| Beyond exemption conditions | Re-evaluate classification |
Practical Verification Note
Review ageing of every advance outstanding as on 31 March before claiming exemption.
Step 5 – Opening Balance Mismatch Framework
| Scenario | Practical Resolution |
|---|---|
| Opening DPT-3 differs from previous year's closing | Prepare reconciliation and obtain confirmation |
| Director loan mismatch | Verify ledger balances |
| ICD mismatch | Verify confirmations |
| Share application money mismatch | Verify allotment records |
| CC / OD mismatch | Match with books and bank statements |
| HUF / LLP loan | Review exemption eligibility separately |
Verification Principle
Current Year Opening Balance should ordinarily reconcile with the Previous Year's Closing Balance, subject to documented adjustments and reconciliation.
Step 6 – Balance Sheet Reconciliation Framework
Before filing DPT-3, perform a complete reconciliation with audited financial statements.
| Particulars | Amount |
|---|---|
| Secured Borrowings | XXX |
| Unsecured Borrowings | XXX |
| Director Loans | XXX |
| Inter-Corporate Borrowings | XXX |
| Other Reportable Receipts | XXX |
| Less: Non-Reportable Liabilities | XXX |
| Amount Reportable in DPT-3 | XXX |
Reconciliation Formula
Amount Reportable in DPT-3 = Reportable Borrowings and Receipts − Non-Reportable Liabilities
Common Error: Assuming Balance Sheet liabilities automatically equal DPT-3 disclosures.
Step 7 – Auditor's Certificate
| Filing Type | Auditor Certificate |
|---|---|
| Exempted Receipts Only | Generally Not Required |
| Deposit Return | Required |
| Combined Filing | Required |
| One-Time Return | Required |
Best Practice
Even where not mandatory, obtain independent verification of balances before filing.
Step 8 – Key Compliance Risk Checkpoints
| Risk Area | Preventive Action |
|---|---|
| Late Filing | File before 30 June |
| Incorrect Purpose Selection | Review before submission |
| Omission of Bank Borrowings | Verify all facilities |
| Wrong Director Loan Classification | Verify exemption conditions |
| Share Application Delays | Review timelines |
| Customer Advance Ageing | Review periodically |
| Unreconciled Figures | Match with audited books |
Penalty Formula
Penalty = ₹5,000 + ₹500 per day of continuing default
Professional Documentation File
Maintain the following documents along with DPT-3 working papers:
| Document | Purpose |
|---|---|
| Audited Financial Statements | Source of disclosures |
| Loan Confirmations | Verification of balances |
| Director Loan Declarations | Support for exemption claims |
| Share Application Records | Verification of timelines |
| Customer Advance Ageing Report | Verification of exemption conditions |
| Previous Year's DPT-3 | Opening balance reconciliation |
| Internal Reconciliation Working Papers | Audit trail and documentation |
| Auditor Verification Note | Internal compliance support |
Best Practice
Maintain a complete DPT-3 compliance file even where an auditor's certificate is not mandatory.
Private Company Filing Checklist – FY 2025–26
☐ Purpose selected correctly
☐ Date of closing entered as 31.03.2026
☐ Net worth verified from audited Balance Sheet
☐ All CC / OD facilities reviewed
☐ Working capital facilities reviewed
☐ Bank term loans reviewed
☐ Director loans verified
☐ Inter-corporate borrowings identified
☐ Share application money reviewed
☐ Customer advance ageing reviewed
☐ Opening balances reconciled
☐ DPT-3 matched with audited books
☐ Exclusions verified
☐ Auditor confirmation obtained
☐ DSC validity checked
☐ Filing completed before 30 June 2026
Frequently Asked Questions
Q1. Should a company with no loans or deposits file DPT-3?
Companies should evaluate their filing obligation based on facts and applicable requirements. Many professionals adopt a conservative NIL filing approach to avoid future MCA queries.
Q2. Are CC, OD and Working Capital facilities reportable?
Yes. Outstanding banking facilities generally require reporting under the applicable exempted category.
Q3. Should interest be included?
Interest accrued and due is generally included. Interest accrued but not due is generally excluded.
Q4. Does resignation of a director affect an existing director loan exemption?
Generally no. The position at the time of receipt is critical.
Q5. Is a loan from a director's HUF covered under the director loan exemption?
Generally no. The exemption applies to the director in an individual capacity.
Q6. How should customer advances outstanding beyond the exemption period be evaluated?
Such cases require separate examination as exemption conditions may cease to be satisfied.
Q7. Is share application money exempt indefinitely?
No. Applicable timelines must be monitored carefully.
Q8. What if the opening balance does not match last year's closing DPT-3?
Prepare a proper reconciliation and obtain confirmation before filing.
Q9. Is an auditor's certificate required where only bank loans exist?
Generally not, if only exempted receipts are being reported.
Q10. Are trade creditors and salary payable reportable?
No. These are generally outside the DPT-3 reporting framework.
Q11. How should corporate credit card dues be treated?
Review the underlying banking arrangement and accounting classification. Where they represent an outstanding banking facility, reporting under Column 15(c) may be appropriate.
Q12. Is a fully repaid loan reportable?
No. DPT-3 generally reports outstanding balances as on 31 March.
Q13. Are MTM losses reportable?
No. MTM losses are accounting adjustments and generally do not represent receipts of money.
Q14. How should loans from RBI-regulated NBFCs be evaluated?
Such loans should be examined under the relevant exemption category based on the nature of the lender and transaction.
Q15. Are Government grants and incentives reportable?
Generally no. These are ordinarily not treated as deposits or borrowings for DPT-3 purposes.
Five Numbers Every DPT-3 Filer Must Verify
| Particulars | Verification Point |
|---|---|
| Net Worth | Column 8 |
| CC / OD Outstanding | Column 15(c) |
| Director Loan Outstanding | Column 15(h) |
| Opening vs Previous Closing | Reconciliation |
| Advances Outstanding | Ageing Review |
Conclusion
Form DPT-3 is no longer a routine ROC filing. It has evolved into a significant disclosure mechanism through which regulators assess a company's borrowing profile, exempted receipts, deposit compliance and overall financial reporting discipline.
Most filing disputes arise from incorrect purpose selection, omission of bank borrowings, misclassification of director loans, ageing issues relating to advances and share application money, and failure to reconcile disclosures with audited financial statements.
A robust DPT-3 filing should therefore be supported by detailed reconciliation, verification of exemption conditions, proper documentation of outstanding balances and timely filing before the statutory deadline.
A few hours spent on reconciliation and review today can prevent substantial compliance exposure and regulatory scrutiny tomorrow.
Legal References: Rule 2(1)(c), Rule 16 and Rule 16A of the Companies (Acceptance of Deposits) Rules, 2014; Sections 73 to 76 of the Companies Act, 2013; MCA Guidance; Professional Guidance and FAQs on DPT-3 Reporting.
