MCA Extended AOC-4 & MGT-7 Deadlines: The Paragraph 4 Catch That Can Still Cost You

MCA extends AOC-4 to 31 Dec 2026 and MGT-7 to 31 Jan 2027, but miss the new date and fees run from the original due date. Read the catch.

Sneha Das

10/27/20264 min read

Breathing Room, With a Condition Attached

On 24th October 2026, the Ministry of Corporate Affairs issued General Circular No. 05/2026, relaxing additional fees and extending the time for filing financial statements and annual returns for FY 2025-26 under the Companies Act, 2013. For a company that held its AGM on 30th September, the usual AOC-4 date of 30th October was less than a week away when the circular arrived, so the relief came at just the right moment.

It is also easy to read too much into it. Many company directors in Kolkata and across West Bengal have heard “extension” and assumed the whole matter is postponed. It isn’t. Here is exactly what changed and what didn’t.

What MCA Actually Announced

The relief applies to FY 2025-26 filings only.

Three Things the Circular Does Not Do

1. It doesn’t waive the normal filing fee. Only the additional fees are relaxed. The regular fee for each form is still payable.

2. It doesn’t extend the AGM date. The circular covers the two filings above and does not move the date by which the annual general meeting had to be held. A late AGM is a separate default, so don’t treat this circular as covering it.

3. It doesn’t stop the clock for good. This is the part most people miss. Paragraph 4 of the circular says that any filing made after the relaxed period attracts all fees, including additional fees, from the date the filing was originally due under the Act, not from 31st December or 31st January.

What Paragraph 4 Looks Like in Rupees

Assume an AGM on 30th September 2026 and additional fees of ₹100 per day. These are illustrative figures, so check the exact position for your form.

Missing the relaxed date by a single day brings back the entire fee from the original due date.

Who Is Covered

Companies filing the AOC-4 variants listed above, including NBFC (Ind AS) forms
Small companies and OPCs filing MGT-7A
One Person Companies, whose AOC-4 originally fell due on 27th September 2026. The circular is framed around the forms and the financial year, and published commentary reads it as covering filings whose original date has already passed. Confirm this against the circular text for your case.

Not covered: other forms such as ADT-1, financial years other than FY 2025-26, and anything under the Income-tax or GST laws. The circular is under the Companies Act only.

Don’t Wait for 31 December: A Pre-Filing Checklist

The extension is useful for companies that are genuinely not ready, and a trap for those who just keep delaying. Work through these now:

Audited financial statements signed, with the auditor’s report and UDIN
Board’s report approved, AGM held, and minutes recorded
Valid DSCs for the directors and the auditor
Directors’ DIN status checked, so no filing stalls on a disqualified or deactivated DIN
Applicability of CFS and XBRL confirmed for your company
Director remuneration in the accounts matched to Form 16 and TDS returns
Loans, deposits and MSME payables reviewed, since these feed into DPT-3 and MSME-1 as well

A Quick Word on the Standard Deduction

Because directors often draw salary from their own company, this question comes up regularly. The Standard Deduction under Section 16 of the Income Tax Act is a flat deduction available to salaried individuals and pensioners, currently ₹75,000 under the new regime and ₹50,000 under the old regime for FY 2025-26. It applies to a director only on remuneration taxed as salary, not on sitting fees, and it never applies to the company itself. It also has no bearing on AOC-4 or MGT-7 or their fees. The practical link is simply that the remuneration figure in your accounts should match what the director reports in their own return.

What Continued Default Actually Costs

Beyond additional fees, a company that fails to file financial statements or annual returns for three consecutive financial years exposes its directors to disqualification under Section 164(2) of the Companies Act. The circular does not amend that provision. If an earlier year is also pending, deal with it now rather than assuming it will sort itself out.

Conclusion

MCA’s extension to 31st December 2026 for AOC-4 and 31st January 2027 for MGT-7 is real relief, but narrow relief: additional fees only, FY 2025-26 only, no AGM extension, and a fee clock that restarts from the original due date the moment you miss the new one. The practical approach is to treat the relaxed dates as a buffer, not a target, and file as soon as your accounts are final.

Frequently Asked Questions

Q1: What are the new due dates for FY 2025-26?
A: AOC-4 and its variants by 31 December 2026, and MGT-7 and MGT-7A by 31 January 2027, without additional fees.

Q2: Are filing fees waived?
A: No. Only additional fees are relaxed. The normal fee for each form is payable.

Q3: Has the AGM deadline been extended?
A: No. The circular does not extend the AGM date.

Q4: What happens if I file after 31 December or 31 January?
A: All fees, including additional fees, are payable from the original due date for the filing, not from the extended date.

Q5: Does this apply to OPCs, small companies and NBFCs?
A: Yes, the listed forms include MGT-7A and the NBFC (Ind AS) variants. OPCs whose original date has passed should confirm their position against the circular.

Q6: Does it change income tax or GST deadlines?
A: No. It is a Companies Act relaxation only.

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