Recent Changes in ROC Annual Filing Forms & Procedures for FY 2024–25

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As we step into the annual compliance season for FY 2024–25, every company registered under the Companies Act, 2013 must gear up for their ROC (Registrar of Companies) annual filings. The Ministry of Corporate Affairs (MCA), through its MCA V3 portal, has rolled out several new changes in forms, disclosures, and filing procedures that significantly impact directors, company secretaries, compliance officers, and auditors.

The shift from MCA V2 to MCA V3 signals a move towards greater transparency, real-time validations, structured data, and increased accountability. Companies must prepare in advance to avoid last-minute issues and hefty penalties.

This guide provides a detailed breakdown of the latest updates, key due dates, form-wise changes, and compliance calendar for FY 2024–25.

Holding of Annual General Meeting (AGM)

  • Due Date:
    • 30th September 2025 (for companies following April–March FY).
  • Agenda:
    • Adoption of financial statements
    • Approval of Board’s Report
    • Appointment/Reappointment of statutory auditors
    • Declaration/approval of dividends (if any)
  • Exemption:
    • One Person Companies (OPCs) and Small Companies are not required to hold an AGM.

Filing of Financial Statements – Form AOC-4

  • Due Date:
    • Within 30 days of AGM → 29th October 2025 (if AGM held on 30th Sept).

New Changes in AOC-4 (MCA V3 – 2025)

  • Disclosures Required:
    • POSH complaints (pending >90 days)
    • Compliance with the Maternity Benefit Act
    • Gender-wise employee count
  • Photographs Upload:
    • Registered office photos (inside & outside with company name board, director present inside photo).
  • Format: Filing in XBRL + PDF.
  • Linked Annexures:
    • AOC-1 (subsidiary/associate) – linked form
    • AOC-2 (related party transactions) – linked annexure
    • CSR-2 (CSR reporting) – now linked to AOC-4
  • Validation:
    • Real-time web-based validations, auto-prefill from previous years, stricter checks.

Filing of Annual Return – Form MGT-7 / MGT-7A

  • Due Date:
    • Within 60 days of AGM → 29th November 2025 (if AGM held on 30th Sept).

New Changes in MGT-7 / MGT-7A (MCA V3 – 2025)

  • Shareholding Pattern:
    • Detailed break-up: Promoter vs Non-Promoter, Resident vs Non-Resident, Gender-wise classification.
  • Board/Committee Meetings:
    • Dates, quorum, attendance summary (not just count).
  • Directors/KMP:
    • Gender, nationality, tenure, ID proof number.
  • Shareholders’ Details:
    • Excel-linked sheet upload (instead of just PDF).
  • Certification:
    • Practising CS certification continues, now covering new disclosures (POSH, maternity, gender data).
  • Validation:
    • Real-time DIN/PAN checks with MCA database.

 

 AOC-4 (Old vs New)

Aspect Old (MCA V2) New (MCA V3 – 2025)
Mode of Filing Offline PDF-based e-form Web-based + Excel utility
Attachments FS, Board Report, Auditor’s Report Mandatory linked annexures (AOC-1, AOC-2, CSR-2), photos
Subsidiary/Associate Disclosure AOC-1 as attachment AOC-1 as linked form
RPT Disclosure AOC-2 as attachment AOC-2 as linked annexure
CSR Reporting CSR-2 filed separately CSR-2 integrated with AOC-4
Board Report General disclosures Additional: POSH, maternity, gender data
Validation Limited checks Real-time validations, stricter checks
Office Verification Not required Mandatory photos
Signatory Director/CS/CFO Same, plus IRP/Liquidator in CIRP cases

 

MGT-7 / MGT-7A (Old vs New) 

Aspect Old (MCA V2) New (MCA V3 – 2025)
Mode of Filing Offline PDF form Fully web-based form
Applicability MGT-7 for all, MGT-7A for small cos/OPC Continues, but more structured
Shareholding Pattern Broad classification Detailed (promoter/non-promoter, gender, resident)
Board/Committee Meetings Only count of meetings Dates, quorum, attendance
Directors/KMP Names, DIN, designation With gender, nationality, tenure, ID
Certification PCS for some cos. PCS continues, covers new disclosures
Attachments Shareholder list, MGT-8 Excel-linked sheet for shareholder details
Validation Limited checks Auto-prefill, DIN/PAN checks

 

 Important MCA Forms & Due Dates for FY 2024–25

Form Purpose Due Date
DIR-3 KYC / DIR-3 KYC-WEB KYC of all directors 30th September 2025
ADT-1 Auditor appointment/reappointment Within 15 days of AGM → 15th October 2025 (if AGM held on 30th Sept)
MGT-14 Filing of Board/Shareholder resolutions (where applicable) Within 30 days of resolution
CRA-4 Cost audit report (if applicable) Within 30 days of Board meeting for approval
AOC-4 (XBRL) Filing of financial statements (XBRL applicable cos.) 29th October 2025
MGT-7 / MGT-7A Annual Return 29th November 2025
CSR-2 CSR reporting (if applicable) Along with AOC-4 filing
DPT-3 Return of deposits (loans/advances covered) 30th June 2025
MSME-1 Half-yearly return for outstanding dues to MSMEs 30th April 2025 & 31st October 2025
PAS-6 Half-yearly reconciliation of share capital (for unlisted public cos.) 30th May 2025 & 29th November 2025

 

Key Takeaways

  • Heavier filing → AOC-4 now has annexures, photos, CSR integration.
  • Structured reporting → MGT-7/7A needs detailed shareholder, board & gender data.
  • Digital-first → Web-based MCA V3, auto-validation, prefilled data.
  • Action for Companies: Collect documents early, coordinate with auditors/CS, avoid last-minute penalties.

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