Annual Compliance Calendar for Private Limited Companies (2026-27) | Virtual Auditor

Annual Compliance Calendar for Private Limited Companies (2026-27)

📖 Definition — ROC Annual Filing: Mandatory filings with Registrar of Companies under Companies Act: AOC-4 (financial statements) and MGT-7/MGT-7A (annual return) within 30 and 60 days of AGM respectively. Late filing penalty: ₹100/day, no maximum cap.

📖 Definition — AGM: Annual General Meeting — must be held within 6 months from end of financial year (i.e., by 30 September for March year-end companies). First AGM within 9 months of incorporation. Non-holding penalty: ₹1 lakh on company + ₹5,000 on every officer in default.

Q1: April–June (Post Year-End)

30 April: DIR-3 KYC for all directors (annual KYC update). Penalty: ₹5,000 per director for late filing + DIN deactivation.

15 May: TDS returns for Q4 (January–March) — Form 24Q (salary), 26Q (non-salary), 27Q (NRI payments). Late filing fee under Section 234E: ₹200/day up to TDS amount. See TDS filing services.

30 May: ITC-04 (job work returns) for October–March half-year (for annual AATO above ₹5 Cr). GST compliance details.

30 June: Advance tax — first instalment (15% of estimated tax). Section 234C interest at 1%/month for shortfall.

Q2: July–September (AGM & Filing Season)

15 July: FLA Return (Foreign Liabilities & Assets) for companies with FDI/ODI — filed on RBI FIRMS portal. Mandatory for all companies that have received foreign investment.

31 July: Income Tax Return due date for companies NOT requiring audit (rare — most Pvt Ltds require statutory audit). Also Form 61A (Statement of Financial Transactions/SFT) if applicable.

15 September: Advance tax second instalment (45% cumulative).

30 September: AGM must be held by this date (within 6 months of 31 March year-end). Board must approve financial statements and directors’ report before AGM. Board resolution templates available.

Q3: October–December (ROC Filings)

29 October: AOC-4 (financial statements) — within 30 days of AGM. Attachments: audited balance sheet, P&L, cash flow, notes, auditors’ report, directors’ report, board report. Late filing: ₹100/day per form, no cap.

28 November: MGT-7A (annual return for small companies) or MGT-7 (for others) — within 60 days of AGM. Contains: shareholding pattern, director details, meeting details, share transfer details.

31 October: Income Tax Return for companies requiring audit — due date for FY 2025-26 (AY 2026-27). Includes tax audit report under Section 44AB. ITR filing services.

15 December: Advance tax third instalment (75% cumulative).

Q4: January–March (Closing Compliance)

15 January: TDS returns for Q3 (October–December). GST annual return GSTR-9 (if not already filed — due 31 December but frequently extended).

15 March: Advance tax final instalment (100%). Last date for tax-saving investments under Section 80C for the current FY.

31 March: Financial year-end. Ensure all statutory registers are updated: register of members, register of directors, register of charges. Conduct physical verification of assets. Reconcile inter-company balances if part of a group. Ensure governance checklist is completed.

🔍 Practitioner Insight — CA V. Viswanathan

The penalty structure for ROC non-compliance has become genuinely painful since the 2018 amendments. AOC-4 filed 6 months late: ₹18,000 penalty (₹100 × 180 days). Both AOC-4 and MGT-7 filed 1 year late: ₹73,000+ combined. I have seen companies with 3 years of non-filing facing ₹2-3 lakh ROC penalties — more than the cost of 3 years of compliance. At Virtual Auditor (IBBI/RV/03/2019/12333), our annual compliance package covers everything — ROC, IT, GST, TDS — for ₹25,000-50,000/year depending on company size. Prevention is always cheaper than cure.

📋 Key Takeaways

  • Regulations: Companies Act Section 92, Section 137, Section 96, Section 139
  • Valuer: CA V. Viswanathan, IBBI/RV/03/2019/12333
  • Methodology: 18 valuation methods, 10,000 Monte Carlo simulations

Frequently Asked Questions

What are the mandatory annual filings for a Pvt Ltd?

ROC: AOC-4 (30 days after AGM) + MGT-7/MGT-7A (60 days after AGM). Income Tax: ITR-6 by 31 October. TDS: quarterly returns. GST: monthly/quarterly returns + GSTR-9 annual return. DIR-3 KYC: by 30 April annually.

What is the penalty for late ROC filing?

₹100 per day per form with no maximum cap. AOC-4 filed 6 months late = ₹18,000. MGT-7 filed 6 months late = ₹18,000. Both together = ₹36,000. Plus additional fees on the MCA portal. Directors may also face personal penalties.

Is statutory audit mandatory for all Pvt Ltd companies?

Yes — unlike LLPs which have a turnover/contribution threshold, ALL private limited companies require statutory audit regardless of turnover. The auditor must be appointed within 30 days of incorporation (first auditor) and at each AGM thereafter.

When must the AGM be held?

Within 6 months from end of financial year = by 30 September for March year-end companies. The gap between two AGMs cannot exceed 15 months. First AGM: within 9 months of incorporation.

How much does annual compliance cost at Virtual Auditor?

Startup/small company (turnover < ₹1 Cr): ₹25,000/year. Growth company (₹1-10 Cr): ₹35,000-50,000/year. Includes ROC filings, IT return, TDS returns, GST returns, and secretarial compliance. Contact +91 99622 60333.

Virtual Auditor — AI-Powered CA & IBBI Registered Valuer Firm
Valuer: V. VISWANATHAN, FCA, ACS, CFE, IBBI/RV/03/2019/12333
Chennai (HQ): G-131, Phase III, Spencer Plaza, Anna Salai, Chennai 600002
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Phone: +91 99622 60333 | Email: support@virtualauditor.in
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