Companies now have more time to complete their annual filings with the Registrar of Companies for financial year 2025-26. The Ministry of Corporate Affairs (MCA) has issued General Circular No. 05/2026, dated 24 October 2026, which allows financial statements to be filed up to 31 December 2026 and annual returns up to 31 January 2027 without additional fees. The relief is useful, but it is narrower than it looks. It covers only the filing of two sets of e-forms, and it does not move the date by which the annual general meeting (AGM) had to be held. This article explains what the circular says, what it does not say, and how to plan the next three months.
What the MCA has allowed
The circular records that the Ministry received representations from stakeholders asking for more time to file the annual statutory forms under the Companies Act, 2013 for FY 2025-26. To help companies complete these filings, the MCA has decided that companies may file:
- Financial statements for FY 2025-26 in e-forms AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS), up to 31 December 2026; and
- Annual returns for FY 2025-26 in e-forms MGT-7 and MGT-7A, up to 31 January 2027,
in each case without payment of additional fees.
Because the list of AOC-4 variants is wide, the relief reaches standalone financial statements, consolidated financial statements, XBRL filers, and NBFCs that follow Ind AS, whether filing standalone or consolidated statements.
What the circular does not change
The AGM deadline stays where it was
The circular states clearly that it must not be read as extending the statutory time for holding AGMs. Companies that have not followed the relevant statutory timelines remain liable under the relevant provisions of the Act. In other words, the extra time is for uploading the forms, not for approving the accounts at a general meeting.
A company that has already held its AGM on time simply gets a longer window to file. A company that has not yet held its AGM should not treat this circular as a reason to wait.
Missing the new dates brings back the full fees
The circular also warns that any filing made after the period of this relaxation will attract all fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014, counted from the date on which the filing was originally due under the Act. So if a company misses 31 December 2026 for its AOC-4, the additional fee is not calculated from 1 January 2027; it is calculated from the original due date. That makes a late filing after the extended date more costly than it might first appear.
Other filings are outside the circular
The circular deals only with FY 2025-26 financial statements and annual returns in the e-forms named above. It does not mention other company filings, and it has no bearing on income-tax or GST due dates. A separate MCA relaxation for filing the cost audit report in Form CRA-4 has been announced, and we covered it in an earlier update; each relaxation should be read on its own terms.
Who should pay attention
- Private and public companies that are still finalising their AOC-4 or annual return for FY 2025-26.
- Groups with subsidiaries, since AOC-4 (CFS) for consolidated statements is included in the relaxation.
- Companies filing in XBRL, which often need more preparation time for tagging and validation.
- NBFCs following Ind AS, as both AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) are covered.
- Companies filing MGT-7A, which is covered along with MGT-7.
- Directors and promoters living outside India, who usually need extra time to review and digitally sign documents, and who should plan signatures well before the new dates.
Practical points before you file
Check the AGM position first
Confirm whether the AGM for FY 2025-26 was held within the time allowed under the Act. If it was not, discuss the position with your advisers now, because the circular expressly keeps the company liable for any lapse on that front.
Keep the order of filing in mind
The two deadlines are a month apart. Treat 31 December 2026 as the target for the financial statements and 31 January 2027 for the annual return, and avoid leaving the AOC-4 to the last few days of December.
Line up the supporting documents
Before uploading, make sure the signed financial statements, auditor’s report, Board’s report and the related attachments are final, and that the details in the annual return (shareholding, directors and meetings) match the company’s registers. Differences between what is reported in AOC-4 and MGT-7 or MGT-7A are worth resolving before either form is filed.
Digital signatures and approvals
Check that the digital signature certificates of the signing directors and professionals are valid and registered. Where a director is travelling or lives abroad, arrange the signing schedule in advance.
What you should do
- Note the two dates: 31 December 2026 for FY 2025-26 financial statements (AOC-4 and its variants) and 31 January 2027 for annual returns (MGT-7 and MGT-7A).
- Confirm that your AGM was held on time; the circular does not extend AGM timelines.
- Do not plan to file after these dates. A filing after the relaxation period attracts additional fees from the original due date.
- Finalise accounts, reports and registers now, and fix any mismatch between the financial statements and the annual return.
- Check digital signatures and schedule sign-offs, especially for directors outside India.
- If you are unsure which AOC-4 form applies to your company, or how the AGM position affects your filings, speak to your chartered accountant or company secretary early.
Source: Taxmann, report on MCA General Circular No. 05/2026.
