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 clocks cannot run from an AGM: AOC-4 is due within 180 days of the financial year-end (Sec 137 proviso), and MGT-7A within 60 days of the date an AGM would have been due — six months from the year-end, so counted from 30 September, about 29 November for a 31 March year-end. 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: DPT-3 (30 June, per company — extended to 31 July 2026 for FY 2025-26 by MCA General Circular 02/2026) and MSME Form I (30 April and 31 October, half-yearly). DIR-3 KYC is per director and is no longer annual: from 31 March 2026 it is filed once every three years, by 30 June of the year it falls due (G.S.R. 943(E) dated 31 December 2025). MCA extends individual dates by circular — check the current notification. 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.
