ROC Additional Fee: Why It's Been Uncapped Since 2018
Late-filing penalties usually have a ceiling somewhere — a maximum number of days, a cap as a multiple of the fee, something. ROC additional fees for AOC-4, MGT-7/MGT-7A, and ADT-1 don't. Since 1 July 2018, it's been a flat ₹100 per day, for every day the filing is late, with no ceiling and no grace period.
The Normal Fee: Slabbed by Paid-Up Capital
Before late filing even enters the picture, the normal filing fee under the Companies (Registration Offices and Fees) Rules 2014 is slabbed by paid-up share capital:
| Paid-up share capital | Normal filing fee |
|---|---|
| Up to ₹1 lakh (or no share capital) | ₹200 |
| ₹1 lakh – ₹5 lakh | ₹300 |
| ₹5 lakh – ₹25 lakh | ₹400 |
| ₹25 lakh – ₹1 crore | ₹500 |
| Above ₹1 crore | ₹600 |
This slab applies to AOC-4 (financial statements), MGT-7/MGT-7A (annual return), and ADT-1 (auditor appointment) alike.
The Additional Fee: Flat, Uncapped, Since 2018
Once the due date passes, Section 403 additional fee kicks in at a flat ₹100 per day — not a percentage, not tiered by capital slab, and critically, not capped. A filing that's six months (roughly 180 days) late owes approximately ₹18,000 in additional fee on top of the normal capital-slab fee, entirely independent of company size. A large company with ₹600 normal fee and a tiny company with ₹200 normal fee pay identical additional fees for identical delay — the slab only affects the base fee, never the per-day penalty.
There's no grace period either. The additional fee starts accruing from the day immediately after the due date, with no buffer window before the ₹100/day clock starts.
The Repeat-Default Multiplier — Flagged, Not Modelled
Beyond the standard flat rate, a "higher additional fee" provision can apply to companies that have failed to file the same document for two or more consecutive financial years — a multiplier on top of the standard ₹100/day rate for repeat non-filers. The exact multiplier mechanics are a separate, narrower rule from the standard late-filing case most engagements deal with, and worth flagging specifically when a client has a multi-year filing gap rather than a single late filing.
Frequently Asked Questions
Is the ₹100/day additional fee the same for AOC-4, MGT-7/7A, and ADT-1?
Yes — the flat ₹100/day rate applies uniformly across AOC-4, MGT-7/MGT-7A, and ADT-1 late filings. What differs between filings is only the normal (on-time) fee, which is slabbed by paid-up share capital.
Is there a maximum additional fee, however late the filing is?
No. The additional fee is uncapped — it keeps accruing at ₹100/day for every day of delay, with no ceiling on total accumulated penalty regardless of how many months or years late the filing eventually is.
Does a larger company pay a higher additional fee than a smaller one for the same delay?
No. The ₹100/day rate is flat regardless of paid-up capital — only the normal (base) filing fee is slabbed by capital. A company with a ₹600 normal fee and one with a ₹200 normal fee owe the same additional fee for an identical number of days late.
What if a company hasn't filed the same form for multiple consecutive years?
A separate "higher additional fee" provision can apply for repeat non-filing across two or more consecutive financial years, layering a multiplier on top of the standard rate. This is a distinct, narrower scenario from a single late filing and needs its own specific check rather than the standard ₹100/day computation.
CORAA's ROC Additional Fee Calculator computes the normal capital-slab fee plus the uncapped ₹100/day additional fee off the actual due date and filing date, so the total exposure is quantified precisely rather than estimated by rough month-count.