ROC annual compliance FY 2025-26: the AGM sets four other deadlines, and Rs 100 a day never stops

Most founders track a single date — 30 September, the AGM.

What gets missed is that the AGM does not stand alone. It sets three more deadlines behind it, and each of those is computed from the date the AGM is actually held, not from a fixed date in the calendar.

# The full sequence for FY 2025-26

And separately, on the same day as the AGM:

| DIR-3 KYC | 30 September 2026 | ₹5,000 per director, and the DIN deactivates |

# The three things that go wrong

One — ADT-1 falls into a blind spot. It is due 15 days after the AGM, which puts it between the AGM everyone is focused on and the AOC-4 deadline everyone is planning for. It is the shortest window in the sequence and the easiest to lose.

Two — the AOC-4 fee has no cap. ₹100 a day, and it simply keeps running. A filing forgotten for a year is ₹36,500. There is no ceiling that stops it.

Three — DIR-3 KYC has nothing to do with the AGM but shares its date. It is a director-level compliance, not a company-level one, and it is frequently missed for exactly that reason — the company secretary is managing the AGM and nobody owns the directors' KYC.

# Holding the AGM earlier moves everything earlier

Because every post-AGM deadline runs from the actual AGM date, an AGM held on 10 September produces:

• ADT-1 by 25 September
• AOC-4 by 10 October
• MGT-7 by 9 November

# LLPs — a lighter load, but uncapped

# DPT-3 — confirm rather than assume

DPT-3 is due 30 June 2026 and applies where the company has deposits or outstanding loans falling within the reporting requirement.

Small private companies frequently conclude it does not apply to them without actually checking — particularly where there are director loans on the books, which is exactly the situation where it can apply.

# Building the calendar backwards

The practical way to run this:

1. Fix the AGM date first, based on when the audit will genuinely be complete
2. AGM + 15 days = ADT-1
3. AGM + 30 days = AOC-4
4. AGM + 60 days = MGT-7
5. Set DIR-3 KYC separately — it is not part of this chain and needs its own owner
6. Check DPT-3 applicability in June rather than assuming

Written by

Prabhakar Kumar

Chartered Accountant (ICAI, Nov 2019)

Founder of VittSphere Technologies. Practicing CA serving 200+ MSME clients across Pune. 86% win-rate at AO and CIT(A) level tax appeals. Writes on Indian taxation, capital gains, and personal finance.