14 September 2026

ROC Annual Filings for Companies and LLPs: The Yearly Cycle

Registrar filings are the compliance most often left until a notice arrives, largely because nothing visibly breaks when they are late. The cost shows up later — in per-day penalties that do not cap, in directors being disqualified, and in a company that cannot complete a transaction because its filings are not current.

For a private limited company

The annual cycle follows the accounts:

Audit of financial statements for the year, completed first — everything else depends on it.
Annual general meeting, to be held within the statutory window after year-end.
Form AOC-4 — filing of financial statements, within 30 days of the AGM.
Form MGT-7 / MGT-7A — annual return, within 60 days of the AGM.
Form ADT-1, where an auditor is appointed or reappointed.
DPT-3, the annual return of deposits and outstanding money received from members, where applicable.
MSME-1, the half-yearly return of outstanding dues to MSME suppliers.

For an LLP

Form 11 — annual return, due within 60 days of the close of the financial year.
Form 8 — statement of account and solvency, due later in the year.
Audit, where turnover or contribution crosses the prescribed thresholds.

An LLP with no business at all still files Form 11 and Form 8. Dormancy is not an exemption.

For every director

DIR-3 KYC is an annual requirement for anyone holding a DIN, filed even when nothing has changed. Miss it and the DIN is deactivated, with a reactivation fee — and a deactivated DIN blocks every other filing the person needs to sign.

Why the penalties bite

Late ROC filings attract additional fees that accrue per day with no upper limit, separate from any penalty. A filing forgotten for two years can cost several times the original professional fee. Continuing default in filing annual returns can also lead to director disqualification and, eventually, to the company being struck off.

None of this is discretionary or negotiable at the counter. The system computes the fee from the date.

Practical points

Work backwards from the AGM date. Once the AGM is fixed, AOC-4 and MGT-7 dates are fixed with it — put them in a calendar, not a to-do list.
Keep the registered office address and email current on the MCA records. Notices go there.
Maintain the statutory registers and minutes through the year. Reconstructing a year of minutes in one sitting before a filing is how errors enter the record.
File DIR-3 KYC for every director in the same sitting. One forgotten director stalls the company's other filings.
If earlier years are already in default, clear them oldest first. The per-day fee keeps running while you decide.

Behind on registrar filings, or unsure what your company owes? Talk to Kunal P Shah & Co.