MCA has given companies extra time to file their FY 2025-26 annual filings without additional fee: AOC-4 by 31 December 2026 and MGT-7 or MGT-7A by 31 January 2027 (General Circular 05/2026, 24 October 2026). Many directors read this as "the due date has moved". It has not, and the difference matters if you file even one day after the window.
How the additional fee works
- The additional fee for AOC-4 and MGT-7 is ₹100 per day, per form, under the Companies (Registration Offices and Fees) Rules, 2014.
- There is no upper limit.
- Inside the relief window, the additional fee is zero. Once the window closes, the fee is counted from the original due date, which is 30 days after the AGM for AOC-4 and 60 days after the AGM for MGT-7.
- The normal filing fee, which depends on share capital, is payable in every case.
A worked example
Take a company that held its AGM on 30 September 2026.
| AOC-4 | MGT-7 | |
|---|---|---|
| Original due date | 30 October 2026 | 29 November 2026 |
| Fee-free up to | 31 December 2026 | 31 January 2027 |
| If filed on 1 January 2027 | 63 days late: about ₹6,300 | Still free |
| If filed on 1 February 2027 | 94 days late: about ₹9,400 | 64 days late: about ₹6,400 |
So missing the window by a single day costs as much as missing the original date by two months. That is the trap.
Penalties are separate from the fee
- Section 137 (AOC-4): the company pays ₹10,000 plus ₹100 a day of continuing default, up to ₹2 lakh. The managing director, the whole-time director in charge of finance or the CFO pays ₹10,000 plus ₹100 a day, up to ₹50,000.
- Section 92(5) (MGT-7): the same structure, with the company capped at ₹2 lakh and each officer in default at ₹50,000.
- The circular does not waive these penalties. It only waives the additional fee.
The bigger risks
- Director disqualification: if a company does not file its financial statements or annual returns for three continuous financial years, every director becomes disqualified for five years under Section 164(2), across every company they are on.
- Strike-off: a company that stops filing can be struck off by the ROC under Section 248.
- Bank and tender checks: lenders and government buyers check MCA filing status before they release limits or award work.
What to do this month
- Confirm the AGM date and that the auditor's report and board approval are signed.
- Check every signatory's DSC and DIN status on the MCA portal.
- File AOC-4 first, because MGT-7 refers to the same year's data.
- Diary 31 December and 31 January now, and aim to finish by mid-December.
Frequently asked questions
Has the AOC-4 due date been extended for FY 2025-26?
MCA General Circular 05/2026 allows AOC-4 for FY 2025-26 to be filed without additional fee up to 31 December 2026. The statutory due date is unchanged, so a filing after 31 December attracts fees from the original due date.
What is the late fee for MGT-7?
₹100 per day with no upper limit, counted from 60 days after the AGM. For FY 2025-26 there is no additional fee if MGT-7 or MGT-7A is filed by 31 January 2027.
Is there a maximum late fee for AOC-4?
No. The additional fee of ₹100 a day has no cap. Separate penalties under Section 137 are capped at ₹2 lakh for the company and ₹50,000 for each officer in default.
Does the extension apply to OPCs and small companies?
Yes, the circular covers the AOC-4 forms and MGT-7 and MGT-7A for FY 2025-26, which includes OPCs and small companies.
Can a late filing fee be waived?
Only through a scheme MCA announces, like the 2026 relief window. Outside such a scheme, the additional fee is payable before the form is accepted.
How Vitt-Marg helps
We handle ROC, cost audit and income-tax compliance for companies and LLPs across Noida, Greater Noida, Ghaziabad and Delhi NCR. Send us your CIN or LLPIN and we will tell you what is pending, what it will cost, and file it before the next deadline.
General information, current as of 4 November 2026, not advice for a specific case. Due dates and fees change with MCA and CBDT notifications. Check with us before acting on it.