Relief from additional filing fees—but no extension of the statutory AGM deadline.
By CA Surekha S Ahuja
The Ministry of Corporate Affairs (MCA), through General Circular No. 05/2026 dated 24 October 2026, has granted companies additional time to file specified annual financial statements and returns for FY 2025–26 without payment of additional fees.
The relief provides a valuable window to complete annual compliance, but its scope is specific: the AGM deadline remains unchanged, and the circular does not grant a blanket waiver of statutory defaults.
Revised filing deadlines
| Forms | Purpose | Extended deadline |
|---|---|---|
| AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | Financial statements and applicable variants | 31 December 2026 |
| MGT-7 and MGT-7A | Annual returns | 31 January 2027 |
The applicable form depends on the company's status and reporting requirements.
What the relief means—and what it does not
1. No additional fees within the extended window
The specified forms for FY 2025–26 may be filed by the respective extended dates without additional fees.
2. The AGM deadline is unchanged
Paragraph 3 expressly clarifies that the circular does not extend the statutory time for holding an AGM. Companies that have missed the applicable AGM timeline remain liable under the relevant provisions of the Companies Act, 2013.
3. Late filing beyond the relaxation can attract additional fees
Under paragraph 4, filings made after the relaxation period will attract applicable fees, including additional fees, calculated from the original statutory due dates.
4. The relief is form-specific
It should not be treated as a blanket extension for every MCA filing, a general amnesty for defaults or a waiver of other statutory obligations.
What companies should do now
Use the additional time to:
Finalise accounts, reconciliations and statutory audits.
Complete the necessary board and shareholder approvals.
Verify the applicable AOC-4 variant and MGT-7/MGT-7A requirement.
Check AGM compliance separately.
File well before the extended deadlines to avoid last-minute errors and portal-related delays.
CA Sahuja Perspective
The MCA's announcement offers practical relief from additional filing fees, but filing relief is not the same as statutory compliance relief.
Companies should use the extended window to complete accurate annual filings while independently addressing any AGM default or other outstanding obligation.
Official reference: MCA General Circular No. 05/2026 dated 24 October 2026, Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013.
Ministry of Corporate Affairs — Official Website
This update is based on the cited circular. Companies should assess their individual compliance position under the applicable law.
