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ROC Compliance Guide

Annual ROC Compliance Checklist for Private Limited Companies in India

By BigMind Advisory Team · · 7 min read

Every Private Limited Company incorporated in India must complete a mandatory set of annual compliance filings with the Registrar of Companies (RoC) to remain in good standing. The key filings are AOC-4 (financial statements) and MGT-7 (annual return), both due within 30–60 days of the Annual General Meeting (AGM). Failure to file attracts ₹100 per day per form with no cap — and persistent non-compliance can lead to director disqualification. BigMind Consulting provides end-to-end annual compliance services for companies across India.

Annual MCA filings and due dates

FormPurposeDue DateLate Filing Penalty
ADT-1Appointment of Statutory AuditorWithin 15 days of AGM₹100/day (no maximum cap)
AOC-4Filing of Financial Statements (Balance Sheet, P&L, Notes, Auditor's Report)Within 30 days of AGM (typically by 30 October)₹100/day beyond due date
MGT-7 / MGT-7AAnnual Return — shareholding details, directorship, charges, and AGM informationWithin 60 days of AGM (typically by 29 November)₹100/day beyond due date
DIR-3 KYCAnnual KYC verification for each director with DIN30 September each yearDIN deactivated; ₹5,000 fee to reactivate
MSME-1Half-yearly return of outstanding dues to MSME suppliers (if applicable)31 October (H1) and 30 April (H2)₹100/day; officer in default liable

Board meetings and AGM requirements

Board of Directors Meetings

  • Minimum 4 board meetings per year
  • Maximum 120-day gap between consecutive meetings
  • 7-day prior notice to all directors (with agenda)
  • Quorum: at least 2 directors or 1/3rd of total directors (whichever is higher)
  • Minutes to be signed and entered in Minutes Book within 30 days

Annual General Meeting (AGM)

  • Must be held within 6 months of financial year end (by 30 September)
  • First AGM: within 9 months from end of first financial year
  • 21-day prior notice to all shareholders
  • Audited financial statements presented and adopted
  • Auditor appointment/reappointment resolution passed
  • ADT-1 filed within 15 days of AGM

Statutory registers every Private Limited Company must maintain

Register of Members (Form MGT-1)
Register of Directors and Key Managerial Personnel (Form MBP-1)
Register of Charges (Form CHG-7)
Register of Loans, Guarantees & Security (Form MBP-2)
Register of Contracts/Arrangements (Form MBP-4)
Minutes Book (Board meetings & General meetings)
Register of Debenture Holders (if applicable)
Share transfer register

Penalties for ROC non-compliance

Non-ComplianceConsequence
Late filing of AOC-4 or MGT-7₹100/day per form with no upper cap — fees accumulate indefinitely until filed
Failure to hold AGMCompany: up to ₹1 lakh; Officers in default: up to ₹1 lakh. Additional ₹5,000/day for continuing default
Failure to maintain statutory registersCompany: up to ₹3 lakh; Officers in default: up to ₹1 lakh
Persistent non-filing (3+ years)Company struck off under Section 248; directors disqualified under Section 164(2) for 5 years
Non-appointment or late appointment of auditor₹300/day for company; ₹10,000 + ₹1,000/day for officers in default

Frequently Asked Questions

What happens if a Private Limited Company misses its ROC filing deadline?

Late filing attracts additional fees of ₹100 per day per form, with no maximum cap — meaning fees accumulate indefinitely. For AOC-4, penalties can escalate to ₹10 lakh if the delay extends significantly. A company that consistently fails to file may be struck off by the Registrar of Companies and its directors may be disqualified from serving on any company for 5 years.

Is a statutory audit mandatory for all Private Limited Companies?

Yes. Every Private Limited Company in India must conduct a statutory audit by a Chartered Accountant regardless of its turnover or profitability. Even companies with zero transactions (dormant companies) must file audited financial statements. This is a mandatory requirement under the Companies Act, 2013.

How many board meetings must a Private Limited Company hold each year?

A minimum of 4 board meetings per year are required, with a maximum gap of 120 days between consecutive meetings. Proper notices must be sent to all directors at least 7 days before the meeting, and minutes must be prepared and entered in the Minutes Book within 30 days of the meeting.

What is ADT-1 and when must it be filed?

Form ADT-1 is filed with the Registrar of Companies to intimate the appointment or reappointment of a statutory auditor. It must be filed within 15 days of the Annual General Meeting (AGM) in which the auditor is appointed. Failure to file ADT-1 attracts penalties.

What is the due date for the Annual General Meeting (AGM) of a Private Limited Company?

A Private Limited Company must hold its AGM within 6 months from the end of its financial year — i.e., by 30 September for companies following the April-March financial year. The first AGM must be held within 9 months from the end of the first financial year.

Need annual ROC compliance support?

BigMind Consulting provides annual compliance packages for Private Limited Companies — AOC-4, MGT-7, AGM coordination, and statutory audit management in India and India.

BigMind Consulting · Annual ROC Compliance & Corporate Secretarial · India