Quick answer: MCA General Circular No. 05/2026 (24 October 2026) lets companies file AOC-4 and its variants for FY 2025-26 without additional fees until 31 December 2026, and MGT-7/MGT-7A until 31 January 2027. The AGM deadline is not extended, and other ROC forms aren't automatically covered.
Companies have more room on annual ROC filings, but only if they read the circular's limits correctly.
What the MCA Has Extended
| Form | What It Is | New Fee-Free Date |
| AOC-4 (and variants) | Financial statements | 31 December 2026 |
| MGT-7 / MGT-7A | Annual return | 31 January 2027 |
AOC-4 variants covered: AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), and AOC-4 CFS NBFC (Ind AS). MGT-7A, the abridged annual return for OPCs and small companies, is covered with MGT-7.
What Is Normally Due
Normally, a company files AOC-4 within 30 days of its AGM and MGT-7 within 60 days, and late filing attracts additional fees per day of delay. The circular removes those fees within the new windows. For a full explainer on forms and deadlines, see annual ROC filing: deadlines, forms and compliance.
What This Extension Does Not Do
- It doesn't extend the AGM deadline. Relief covers the filings, not the meeting
- It covers named forms for FY 2025-26 only. ADT-1 and MGT-14 aren't automatically covered
- It removes additional fees, not the obligation. After the new dates, additional fees return, and commentary on the circular suggests they may be counted from the original due date. Check the circular's wording for your situation
Don't Treat It as Extra Time to Wait
Extended dates push filings to the final days, when portal traffic peaks. File earlier because:
- AOC-4 needs finalized, audited financials, and MGT-7 needs accurate shareholding and director details
- MGT-7 usually follows AOC-4, so a late AOC-4 compresses the annual return window
- Prolonged non-filing has consequences beyond fees, including possible action against the company and its directors
A Practical Filing Plan
- Confirm your AGM date and that it was held within the permitted timeline
- Finalize and sign off audited financial statements
- File AOC-4 well before 31 December 2026
- Prepare MGT-7 or MGT-7A using updated shareholder and director details
- Keep a buffer before 31 January 2027 for corrections
- Check other pending ROC filings, since the circular doesn't extend them
Who Should Pay Particular Attention
- Companies already past their usual due dates and relying on the fee-free window
- Companies still finalizing audits or awaiting the AGM
- OPCs and small companies filing MGT-7A. Not sure your structure fits? See which business structure suits you in Odisha
- Companies with consolidated or XBRL filings, which need more preparation
- Newly incorporated companies facing their first annual filing. Here's how online company registration works, and the Private Limited registration guide for Odisha for local companies
Frequently Asked Questions (FAQ)
Q1. What are the new deadlines for FY 2025-26?
A: AOC-4 and its specified variants without additional fees until 31 December 2026, and MGT-7/MGT-7A until 31 January 2027.
Q2. Which circular grants this extension?
A: MCA General Circular No. 05/2026, dated 24 October 2026.
Q3. Does this extend the AGM deadline?
A: No. It relaxes additional fees on the named filings only.
Q4. Is MGT-7A covered?
A: Yes, alongside MGT-7.
Q5. Does this cover all ROC forms?
A: No. Forms like ADT-1 and MGT-14 are not automatically covered.
Q6. What happens if I file after the new dates?
A: Additional fees for delay apply.
Q7. Can I file before the new dates?
A: Yes, and it's advisable. The extension sets the last fee-free date, not the earliest.
Use the Window to File Properly
Use the time to finalize accounts and file accurately, not to treat 31 December and 31 January as the target. For help preparing AOC-4 and MGT-7, choose a trusted compliance partner, see our company compliance guide.