Most ROC due dates run off the Annual General Meeting (AGM) date, not the financial year-end: AOC-4 within 30 days of the AGM (Sec 137), MGT-7/MGT-7A within 60 days (Sec 92), and ADT-1 within 15 days of the AGM at which the auditor was appointed (Sec 139). Since companies must ordinarily hold their AGM within 6 months of FY-end (i.e. by 30 September for a 31 March year-end, subject to extension), the default AGM date used here is 30 September.
One-Person Companies do not hold an AGM at all (Sec 96 proviso), so their AOC-4 and MGT-7A clocks run from the financial year-end instead — 180 days and 60 days respectively. Small companies and OPCs both file the abridged MGT-7A rather than the full MGT-7; Section 8 companies can never use MGT-7A because Sec 2(85) excludes them from the small-company definition outright, regardless of size.
A second set of obligations runs on fixed annual or half-yearly calendar dates, independent of any one company's AGM: DIR-3 KYC (30 September, per director), DPT-3 (30 June, per company), and MSME Form I (30 April and 31 October, half-yearly). A third set is event-triggered rather than dated at all — BEN-2 (30 days from a BEN-1 declaration) and the board-level MBP-1/DIR-8 disclosures at the first Board meeting of the year. CSR-2 sits apart again: filed as a post-AOC-4 addendum only where CSR applies, on a date MCA has historically set by circular rather than a standing Rule.
A private limited company (not small, not Section 8) has FY-end 31 March 2026, holds its AGM on the default date of 30 September 2026, has paid-up capital of ₹2 Cr and turnover of ₹50 Cr — below both XBRL triggers.
