ROC Annual Filing — AOC-4, MGT-7A

AOC-4: filing of financial statements (Balance Sheet, P&L, notes, audit report) — due 30 days after AGM. MGT-7/7A: Annual Return with shareholding pattern, director details, and company overview — due 60 days after AGM. DIR-3 KYC: annual KYC of every director holding a DIN — due 30 September each year. Failure to file DIR-3 KYC: the director's DIN is deactivated, preventing signing of any ROC form until KYC is filed with a ₹5,000 late fee.

DIR-3 KYC is due every year by 30 September. If not filed by this date, the DIN is marked 'deactivated due to non-filing of DIR-3 KYC'. The DIN is reactivated by filing Form DIR-3 KYC with a late fee of ₹5,000 (₹5,000 for DIR-3 KYC-Web too). While the DIN is deactivated, the director cannot sign any MCA form — no filings can be made for the company until the director's DIN is active. All directors (even retired directors who held DIN in the past) must file annual DIR-3 KYC.

Section 96: every company (except OPC) must hold its AGM within 6 months of the close of the financial year — by 30 September. The first AGM must be held within 9 months of the close of the first financial year. If the AGM is not held, the Registrar can call the AGM under Section 97. Section 99: penalty for not holding AGM — up to ₹1 lakh on the company and each officer in default. Members can approach NCLT under Section 97 to order an AGM.

Section 173: every company must hold at least 4 Board meetings in a year, with a gap of not more than 120 days between two consecutive meetings. OPCs, small companies, and dormant companies: at least one Board meeting per half-year with a 90-day gap. Meetings can be held via VC/OAVM for any agenda item (Ministry circular during COVID extended this permanently under the Companies Act framework). Penalty for non-compliance: ₹25,000 per director per default under Section 173.

Form INC-22A (ACTIVE — Active Company Tagging Identities and Verification) was a one-time filing required by 25 April 2019 for companies incorporated before 31 December 2017. Companies that did not file ACTIVE are tagged as 'ACTIVE non-compliant' — they cannot file certain ROC forms (including change of director, registered office, or capital). Current filers must still file AOC-4 and MGT-7 annually — ACTIVE tagging does not substitute for annual returns.