MCA21 V2 shuts down today: What every private company must do before V3-only filing begins July 1, 2026

MCA21 V2 shuts down today: What every private company must do before V3-only filing begins July 1, 2026

A founder sits down on the evening of June 30, 2026 to file an overdue AOC-4, opens the old MCA21 V2 login she has used for years, and finds the form will no longer accept her submission. Her company secretary is on leave. Her Digital Signature Certificate is a Class 2 token that V3 will reject. And the 90% penalty waiver she half-remembered reading about expires in two weeks. By the time she sorts it out, the additional fees on three years of pending filings have ballooned back to full rate. This is not a hypothetical — it is the single most common scenario the Registrar of Companies will see across the first half of July 2026, because today is the last day of the old portal.

From July 1, 2026, MCA21 V2 is permanently decommissioned. Every fresh filing, every public document download, every master-data search, and every Digital Signature Certificate operation happens on MCA21 V3 only. If your company has not migrated its login, associated a valid Class 3 DSC, and cleared its filing backlog, you are about to discover how expensive a missed transition can be. Here is exactly what the law requires, what it costs to get it wrong, and the step-by-step actions to take this week.

What the law actually requires

There is a common misconception that "the portal changing" is a technical inconvenience with no legal weight. It is the opposite. The filing obligations under the Companies Act, 2013 do not pause because the Ministry is migrating infrastructure. The statutory deadlines, the forms, and the penalties all continue to run — only the channel through which you discharge them has changed.

The core annual filing obligations remain unchanged. Under Section 137 of the Companies Act, 2013, every company must file its financial statements in Form AOC-4 within 30 days of the Annual General Meeting. Under Section 92, the annual return must be filed in Form MGT-7 (or MGT-7A for small companies and One Person Companies) within 60 days of the AGM. Director KYC under Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014 is due in Form DIR-3 KYC by September 30 each year. Return of deposits under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014 is filed in Form DPT-3 by June 30. All of these are now V3-only forms.

Two changes are non-negotiable on the new portal. First, V3 mandates a Class 3 Digital Signature Certificate issued by a CCA-licensed certifying authority for every director, KMP, and authorised signatory — Class 2 certificates are no longer accepted. Second, each signatory must individually log in to V3 and associate their DSC through the FO Services → Associate DSC pathway before any form bearing their signature can be uploaded. A company with three directors needs three separately associated Class 3 DSCs. This cannot be done at the last minute through a single CS login.

Running alongside the cutover is the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), introduced by MCA General Circular No. 01/2026. The scheme allows companies to clear pending annual filings — all variants of AOC-4, MGT-7 and MGT-7A, and ADT-1 — by paying only 10% of the additional fees, an effective waiver of roughly 90%. CCFS-2026 closes on July 15, 2026. After that date, the additional-fee relief disappears and the standard penalty structure applies in full.

Practical implications

When founders ignore the transition, three things happen — and they compound.

The first is the additional fee under Section 403. Late filing of AOC-4 or MGT-7 attracts an additional fee of ₹100 per day, per form, with no upper cap. A company that is two years behind on both forms is staring at four separate ₹100-per-day meters running simultaneously. This is precisely the liability CCFS-2026 cuts by 90% — and precisely the liability that snaps back to full force on July 16.

The second is penalty under Section 137(3) and Section 92(5) for the default itself, which is separate from the late-filing fee. For a continuing AOC-4 default, the company is liable to a penalty of ₹10,000 plus ₹100 per day of continuing default subject to a maximum of ₹2,00,000, and every officer in default faces a penalty up to ₹50,000. For an MGT-7 default under Section 92(5), the company and every officer in default are liable to ₹10,000 plus ₹100 per day of continuing failure, subject to a maximum of ₹2,00,000.

The third — and the one founders underestimate most — is director disqualification under Section 164(2). If a company fails to file financial statements or annual returns for any continuous period of three financial years, every director of that company is disqualified from being reappointed in that company or appointed in any other company for five years. The MCA21 system flags this automatically. Once V3 fully consolidates filing data, the detection of three-year defaults becomes faster and more systematic, not slower. A blocked DSC migration that quietly stretches a two-year backlog into a three-year one can convert a fee problem into a disqualification problem.

There is a fourth, quieter risk: strike-off under Section 248. The Registrar may strike off a company that has not been carrying on business or has persistent filing defaults. A company that goes dark on V3 because nobody migrated the login is exactly the profile that surfaces in strike-off scrutiny lists.

To make the cost concrete, take a small private company two financial years behind on both AOC-4 and MGT-7A. The additional fee under Section 403 alone runs at ₹100 per day on each form, so by the time the default is roughly 18 months old on the earlier year, a single form has already accrued well over ₹50,000 in additional fees, and there are multiple forms across multiple years compounding in parallel. CCFS-2026 collapses that additional-fee burden to about 10% — which can mean the difference between a few thousand rupees and well over a lakh. On July 16, the same filing is charged at full rate. The arithmetic is why advisers are treating the next two weeks as the most important filing window of the year.

What actually changes on V3 — and what doesn't

It helps to separate the genuine changes from the things founders wrongly assume have changed.

What changes: the portal itself, the DSC class (Class 3 only), the login and DSC-association workflow, and the user interface for several forms. Small companies and One Person Companies now file a simplified single-page AOC-4 and MGT-7A on V3 instead of the older multi-tab forms. Most incorporations and annual filings are processed centrally and in a faceless, randomised manner by the Central Registration Centre, which means there is no "local ROC contact" to lean on if a form is stuck — the system, not a person, is your counterparty.

What does not change: the statutory deadlines, the forms you owe, the signatories who must sign them, and the penalty regime under Sections 92, 137, 164, 403 and 248. The Companies Act, 2013 is unchanged by the migration. A director who assumes the deadline "resets" because the portal moved is making exactly the error that triggers a default. The obligation is the same; only the address has moved.

One practical consequence of the faceless, centralised model is that errors are less forgiving. A form rejected for a DSC mismatch or an un-associated signatory does not get a friendly phone call — it simply does not go through, and the clock keeps running. That is why the DSC association steps below must be completed before, not during, your filing attempt.

Step-by-step: what to do this week

• Confirm your V3 account today. Go to the MCA21 V3 portal and check that your company and each director can log in. V2 credentials do not automatically carry over for every function — verify, don't assume.
• Audit every signatory's DSC. For each director, KMP, and authorised signatory, confirm they hold a valid Class 3 DSC. If anyone is still on Class 2 or has an expired token, order a fresh Class 3 certificate immediately — procurement plus issuance can take a day or more.
• Associate each DSC on V3. Each signatory logs in individually and completes FO Services → Associate DSC. Do this before you attempt to upload any form, not during the upload.
• Pull your filing history and identify the backlog. List every pending AOC-4, MGT-7/MGT-7A, ADT-1, DIR-3 KYC, and DPT-3. Note how many financial years each default spans — anything approaching three continuous years is a Section 164(2) red flag that must be cleared first.
• File under CCFS-2026 before July 15. Any AOC-4, MGT-7/MGT-7A, or ADT-1 backlog should be cleared while the 10%-of-additional-fee relief is live. Treat July 15 as a hard wall; do not leave it to the final day given V3 load and the recent disaster-recovery disruption at the MCA data centre.
• Calendar the recurring V3 deadlines. DPT-3 by June 30, DIR-3 KYC by September 30, AOC-4 within 30 days of AGM, MGT-7 within 60 days of AGM. Put them in writing now so the next cycle never becomes a backlog.
• Run a board minute recording the migration. A short board note confirming DSC association and the compliance status protects directors if any default is later questioned.

FAQ

Can I still file on MCA21 V2 after June 30, 2026?
No. From July 1, 2026, V2 is permanently decommissioned — no fresh filing, no document download, no public search. All filing must be done on MCA21 V3.

My DSC is Class 2 and still valid for another year. Can I use it on V3?
No. V3 accepts only Class 3 DSCs issued by a CCA-licensed certifying authority. A still-valid Class 2 certificate will be rejected, so order a Class 3 replacement before you attempt to file.

What exactly does CCFS-2026 cover, and when does it end?
CCFS-2026 lets companies clear pending AOC-4 (all variants), MGT-7/MGT-7A, and ADT-1 by paying only 10% of the additional fees — about a 90% waiver. It closes on July 15, 2026, after which full additional fees and penalties apply.

I'm two years behind on filings. Is disqualification a risk?
Not yet, but it is close. Director disqualification under Section 164(2) triggers at three continuous financial years of non-filing of financial statements or annual returns. Clear the backlog now — letting it slip into a third year disqualifies every director for five years.

Does the portal migration reset or extend my filing deadline?
No. The deadlines under Sections 92 and 137 are unchanged. AOC-4 is still due within 30 days of the AGM and MGT-7/MGT-7A within 60 days. The migration changes the channel, not the obligation — assuming otherwise is how defaults start.

My company is fully up to date. Do I still need to do anything before July 1?
Yes. Even a compliant company must migrate its V3 login and associate a Class 3 DSC for every director and authorised signatory. If your DSCs aren't associated on V3, your next on-time filing — DIR-3 KYC by September 30, for example — will fail at upload.

For a compliance audit of your company, visit pvtltd.co

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