Company Annual Filing (ROC)

What is company annual filing? Every company registered under the Companies Act, 2013 must file annual returns with the Registrar of Companies (RoC) — AOC-4 (financial statements) within 30 days of AGM, and MGT-7/MGT-7A (annual return) within 60 days of AGM. Late filing attracts penalty of ₹100/day per form with no maximum cap. Persistent non-filing can lead to company being marked "Active non-compliant" and director disqualification under Section 164(2). Virtual Auditor manages the complete annual compliance cycle with deadline tracking and penalty avoidance. Quick Answer: Company Annual Filing (ROC) — Company annual filing services. AOC-4 (financial statements), MGT-7/MGT-7A (annual return) with RoC. Penalty avoidance. By practicing CA firm since 2012.

Company Annual Filing (ROC) is a service offered by Virtual Auditor, an AI-powered CA and IBBI Registered Valuer firm (IBBI/RV/03/2019/12333) led by CA V. Viswanathan (FCA, ACS, CFE, IBBI RV), specialising in statutory compliance and corporate restructuring, from offices in Chennai, Bangalore, and Mumbai since 2012.

Source: Companies Act 2013, Companies (Management and Administration) Rules 2014 Official References: MCA Filing ↗ · Companies Act ↗

Filing Requirements

Regulatory basis: Section 92 (MGT-7), Section 137 (AOC-4), Companies Act 2013. AOC-4 due within 30 days of AGM. MGT-7 due within 60 days of AGM. AGM must be held within 6 months of financial year end.

AOC-4: Financial statements (Balance Sheet, P&L, Cash Flow, Notes), board report, auditor's report. Must be adopted at AGM. For OPCs: within 180 days of year-end.

MGT-7/MGT-7A: Annual return containing: share capital, shareholders, directors, meetings held, compliance status. MGT-7A (simplified) for OPCs and small companies.

Penalty: ₹100/day for each form, for each day of default. Both the company and every officer in default are liable. No maximum cap — penalties can accumulate to lakhs.

Annual Filing — Company vs LLP

Filing	Company	LLP
Financial statements	AOC-4 (30 days after AGM)	Form 8 (Oct 30)
Annual return	MGT-7 (60 days after AGM)	Form 11 (May 30)
Income tax return	ITR-6 (Oct 31)	ITR-5 (Oct 31 if audit)
GST annual return	GSTR-9 (Dec 31)	GSTR-9 (Dec 31)
Late fee	₹100/day per form	₹100/day per form

Recent Engagement — How We Helped

Context: a group of 4 co-founders launching an AI-powered fintech startup in Bangalore.

Challenge: The founders needed to incorporate quickly to sign a term sheet with an angel investor, but had complex requirements — one NRI director, customised Articles of Association with vesting clauses, and simultaneous DPIIT startup recognition for tax benefits.

Our approach: We handled end-to-end incorporation using SPICe+ (INC-32), securing DSC for all 4 directors including the NRI (using foreign address attestation), drafted customised MOA/AOA with founder vesting and anti-dilution provisions, and filed DPIIT recognition immediately post-incorporation.

Outcome: Certificate of Incorporation received in 6 working days. PAN/TAN/GST registration allotted simultaneously through SPICe+. DPIIT recognition approved within 48 hours of incorporation. The angel round closed within 3 weeks of engagement.

This engagement illustrates Virtual Auditor's approach to company annual filing (roc) — combining regulatory expertise with practical execution to deliver results within the client's timeline.

When Is Company Annual Filing (ROC) Not Required?

Annual filing exemption is available only when: (a) the company has been declared dormant under Section 455 (reduced filing requirements apply), or (b) the company has applied for strike-off under Section 248 and the application is pending. All other active companies — including those with zero revenue — must file AOC-4 and MGT-7 annually. Non-filing attracts daily penalty of Rs 100/day (max Rs 5 lakh) per form, director DIN disqualification under Section 164(2), and inability to file any other form until annual filings are current.

If you are unsure whether your situation requires company annual filing (roc), contact us for a free preliminary assessment. We will advise you honestly — including telling you if you do not need our services.

Documents Required

The following documents are needed to initiate the company annual filing (roc) process:

PAN card and Aadhaar of all proposed directors/partners/members, passport-size photographs, proof of registered office address (rent agreement + NOC + utility bill, or ownership proof), Digital Signature Certificate (DSC) for all directors/designated partners, Director Identification Number (DIN) or application for allotment, draft constitutional document (MOA/AOA/LLP Agreement/Trust Deed), declaration and consent from directors/partners (Form INC-9/DIR-2), and professional certificate from a practicing CA/CS/Advocate.

We provide a personalised document checklist after the initial consultation, tailored to your specific entity type and situation. Documents can be shared securely via email or our client portal.

What You Receive

Upon completion of the company annual filing (roc) engagement, you will receive: Certificate of Registration/Incorporation from the relevant authority, PAN and TAN allotment (where applicable), certified copies of constitutional documents (MOA/AOA/LLP Agreement/Trust Deed), digital copies of all filed forms with acknowledgment receipts, and a post-registration compliance checklist with due dates for the first year.

All deliverables are reviewed by CA V. Viswanathan (FCA, ACS, CFE, IBBI RV) before release to ensure accuracy and regulatory compliance.

Updated for FY 2025-26

This service page reflects the latest regulatory requirements as of March 2026, incorporating changes from the Union Budget 2025, recent MCA notifications, CBDT/CBIC circulars, and RBI master directions applicable to company annual filing (roc). Virtual Auditor continuously monitors regulatory updates to ensure all advice and filings are current.

Frequently Asked Questions

What is the penalty for late annual filing?

₹100/day per form (AOC-4 and MGT-7 separately). No maximum cap. Additionally, persistent default (3+ consecutive years) can lead to company strike-off and director disqualification.

When is the AGM due?

Within 6 months from the end of the financial year (i.e., by September 30 for March year-end companies). First AGM: within 9 months from the end of the first financial year.

What if the company has no transactions?

Filing is mandatory even for dormant/inactive companies. NIL returns must be filed. Alternatively, apply for dormant status under Section 455 to reduce compliance burden.

Can you file for previous years (backlog)?

Yes. We handle backlog filings for all previous years. Additional fees for late filing (government penalty + professional fees). Better to clear backlog before penalties compound further.

What are the mandatory annual filings for a company?

AOC-4 (financial statements): within 30 days of AGM. MGT-7/MGT-7A (annual return): within 60 days of AGM. ADT-1 (auditor appointment): within 15 days of AGM. DIR-3 KYC (director KYC): by September 30 annually.

When must AGM be held?

Within 6 months from end of financial year (by September 30 for March year-end companies). First AGM: within 9 months of year-end. Gap between two AGMs: maximum 15 months. Penalty for non-holding: ₹1 lakh on company, ₹25,000 on every officer.

Is secretarial audit needed for private companies?

Only if: paid-up capital ≥₹50 crore or turnover ≥₹250 crore. For other private companies: not mandatory. But secretarial compliance check by CS is recommended to identify compliance gaps before they become penalties.

What is DIR-3 KYC and who must file?

Annual KYC update for every person holding DIN. Form DIR-3 KYC: for first time or change in details. Web form DIR-3 KYC-Web: for no-change annual update. Due by September 30. Penalty for non-filing: ₹5,000 + DIN deactivation.

Step-by-Step Process

Step 2

Get accounts audited by statutory auditor

Step 3

Hold board meeting to approve accounts

Step 4

Hold AGM within 6 months of year-end

Step 5

File AOC-4 within 30 days of AGM

Step 6

File MGT-7/7A within 60 days of AGM