Every October, the same hope circulates in promoter WhatsApp groups: "MCA will extend, it always does." This year, as of mid-October, MCA has announced no extension and no additional-fee waiver for FY 2025-26 annual filings. ICSI has written to MCA (9 October 2026) asking for relaxation till 31 December — a request, not a relief.
Plan on the statutory dates. Here's the full picture, including two changes this year that catch companies out.
The two dates, and what they hang on
For the standard case — AGM held on 30 September 2026:
AOC-4 (financial statements): due 30 October 2026 — 30 days from the AGM. MGT-7 or MGT-7A (annual return): due 29 November 2026 — 60 days from the AGM. Different AGM date? Both deadlines shift with it. Our ROC Filing Deadline Calendar computes the full year for your company type — use it, don't rely on forwards.
The cost of missing: ₹100 per day per form in additional fees, uncapped. Ninety days late on both forms is ₹18,000 before anyone says the word "penalty". And since February 2026, someone can say it — the RoC now adjudicates directly under Section 454, as we explained in RoC adjudication powers. The CCFS amnesty closed on 15 September. This is the first annual filing season where "late" has fast consequences.
Change one: you might be a small company now
From 1 December 2025, the small-company thresholds are paid-up capital up to ₹10 crore and turnover up to ₹100 crore. Thousands of companies have quietly become "small" — which changes this filing season: MGT-7A instead of MGT-7, no cash-flow statement in the financials, two board meetings a year instead of four, and exemption from auditor rotation.
File on last year's assumptions and you'll either over-comply (wasted effort) or — worse — claim small-company treatment you haven't verified. Check the two numbers before your AGM papers are finalised.
Change two: the Board's report got heavier
The Companies (Accounts) Second Amendment Rules, 2025 — effective 14 July 2025 — added detailed POSH compliance data, a Maternity Benefit Act statement, and gender-wise employee numbers to the Board's report. Last year, reports approved before 14 July escaped. This year, nobody does.
This is the single most common defect we're seeing in FY 2025-26 Board reports right now: last year's template, copied forward, missing all three disclosures. It takes an hour to fix in draft. After adoption, it takes a revision — and it will be spotted in any secretarial audit or diligence.
The order the work actually happens
Classify the company (small or not) → finalise accounts → draft the Board's report with the new disclosures → hold the AGM → file AOC-4 within 30 days → file MGT-7/7A within 60 days → keep DIR-3 KYC, DPT-3 and MSME-1 in the same calendar. Our full ROC annual filing calendar for FY 2025-26 lays out every date and every penalty in one place.
CorpCFO's Company Secretarial practice runs this entire cycle for companies on retainer — board papers, AGM, filings, registers — so October is a non-event for our clients. If your October currently looks like a scramble, that's the problem to fix, and it's fixable before the 30th.
AGM on 30 Sept 2026 → AOC-4 by 30 October 2026, MGT-7/7A by 29 November 2026. No MCA extension announced as of mid-October.
From 1 December 2025: paid-up capital up to ₹10 crore and turnover up to ₹100 crore. Newly-small companies get MGT-7A, no cash-flow statement, fewer board meetings.
POSH compliance data, a Maternity Benefit Act statement, and gender-wise employee numbers — mandatory for FY 2025-26 under the July 2025 amendment.
₹100/day/form in additional fees, uncapped — plus direct RoC adjudication of penalties since February 2026, with CCFS amnesty now closed.
ICSI has requested relaxation till 31 December 2026, but nothing is granted. Plan on the statutory dates.
AOC-4 is due in days, not weeks. If your accounts, Board report or AGM papers aren't ready, CorpCFO can still get you filed on time — but only if you call now, not on the 29th.
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