Once the AGM is over, most companies have two ROC filings left for the year, and AOC-4 is the first. It carries the adopted financial statements, the auditor's report and the Board's Report to the Registrar — and since July 2025 it no longer travels alone. Here is the deadline after a 30 September 2026 AGM, which form applies, the new extract e-forms, and what a late filing really costs. Position as on 17 October 2026.
Short answer
Short answer: under Section 137(1) of the Companies Act, 2013, a company files its financial statements in Form AOC-4 within 30 days of the AGM at which they were adopted. For an AGM held on 30 September 2026, file by 29 October 2026 — some count the period to 30 October, but 29 October satisfies both readings. Since 14 July 2025 the filing must be accompanied by e-Forms Extract of Board Report and Extract of Auditor's Report. A late AOC-4 costs ₹100 for every day of delay, with no upper limit.
Due date: 29 or 30 October?
The deadline runs from your AGM date, not from a fixed calendar date. Like ADT-1, the "30 days of the meeting" is counted two ways: including the AGM day gives 29 October for a 30 September AGM, excluding it gives 30 October. Working to the earlier date removes the question. As on 17 October 2026, the MCA has not extended the AOC-4 date for FY 2025-26.
| Company | AOC-4 due for FY 2025-26 |
|---|---|
| AGM held on 30 September 2026 | 29 October 2026 (30 October on the alternative count) |
| AGM held on an earlier date | Within 30 days of that AGM |
| One Person Company (no AGM) | Within 180 days of the year end — 27 September 2026, already passed |
| AGM not held by 30 September | Within 30 days of 30 September, with unadopted statements — see the last section |
AOC-4, AOC-4 CFS or AOC-4 XBRL?
- AOC-4: the standard form for most private and unlisted public companies.
- AOC-4 CFS: filed in addition by a company that has subsidiaries, associates or joint ventures and prepares consolidated financial statements.
- AOC-4 XBRL: required instead of AOC-4 for companies covered by the Companies (Filing of Documents and Forms in XBRL) Rules, 2015 — listed companies and their Indian subsidiaries, companies with paid-up capital of ₹5 crore or more, companies with turnover of ₹100 crore or more, and companies preparing Ind AS financial statements. Banking, insurance, power and NBFCs are outside the XBRL requirement.
- AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS): for NBFCs following Ind AS.
What changed in 2025 — and applies this year
The Companies (Accounts) Second Amendment Rules, 2025 (G.S.R. 357(E) dated 30 May 2025, in force from 14 July 2025) changed the AOC-4 filing in two ways that affect the FY 2025-26 accounts being filed now:
- New linked e-forms. Under the new rule 12(1C), every company filing AOC-4, AOC-4 CFS, AOC-4 XBRL or the NBFC variants must also file e-Form Extract of Board Report and e-Form Extract of Auditor's Report (Standalone) — and the Consolidated extract where consolidated statements are filed. Key content of the Board's Report and the audit report is now captured as data, not only as a PDF attachment.
- New Board's Report disclosures. Rule 8(5)(x) now requires, alongside the statement on the Sexual Harassment of Women at Workplace Act, the number of complaints received in the year, the number disposed of, and the number pending for more than 90 days. A new clause (xiii) requires a statement on compliance with the Maternity Benefit Act, 1961.
In practice, a Board's Report approved in a hurry from last year's template is the most likely place for an FY 2025-26 filing to fall short. Check that both new disclosures are in it before the AGM papers are finalised.
What goes with the form
- Adopted financial statements — balance sheet, statement of profit and loss, cash flow statement (small companies and OPCs are exempt from the cash flow statement) and notes.
- The auditor's report, including the CARO report where it applies.
- The Board's Report with its annexures — AOC-1 for subsidiaries and associates, AOC-2 for related-party contracts where applicable, and the CSR annual report for companies covered by Section 135.
- The Extract of Board Report and Extract of Auditor's Report e-forms filed alongside.
- Certification of the form by a practising Chartered Accountant, Company Secretary or Cost Accountant, and the digital signature of an authorised director.
- The SRN of the ADT-1 filed for the auditor's appointment, which the form asks for.
Late fee and penalty
The normal government fee is ₹200 to ₹600, depending on nominal share capital. The late fee is what matters: ₹100 for every day of delay, with no ceiling, under the Companies (Registration Offices and Fees) Second Amendment Rules, 2018. A delay of 60 days costs ₹6,000; a year costs roughly ₹36,500 — for one form. MGT-7 or MGT-7A, due 60 days after the AGM, carries the same ₹100 a day separately.
| Consequence | Amount or effect |
|---|---|
| Additional fee — AOC-4 filed late | ₹100 per day of delay, no upper limit |
| Penalty on the company — Section 137(3) | ₹10,000, plus ₹100 per day of continuing default, up to ₹2,00,000 |
| Penalty on the managing director, CFO or director in charge — Section 137(3) | ₹10,000, plus ₹100 per day of continuing default, up to ₹50,000 |
| Three continuous years of non-filing — Section 164(2) | Directors disqualified from appointment for five years |
The CCFS-2026 relief scheme, which waived most additional fees on old defaults, has closed. A filing missed now pays the full additional fee.
If the AGM was not held
Section 137(2) covers this. If the AGM was not held by its due date, the company must still file the financial statements — duly signed, with a statement of the fact and reasons that the AGM was not held — within 30 days of the last date on which it should have been held. For FY 2025-26 that clock started on 30 September 2026. Separately, not holding the AGM is its own default under Section 99, and the adopted statements are filed again once the AGM is held.
Frequently Asked Questions
What is the due date for AOC-4 for FY 2025-26?
Within 30 days of the AGM. For an AGM held on 30 September 2026, file by 29 October 2026; some count the period to 30 October, but 29 October is compliant under both readings. As on 17 October 2026, no extension has been notified.
What is the late fee for AOC-4?
₹100 for every day of delay, with no upper limit, in addition to the normal filing fee of ₹200 to ₹600. Section 137(3) separately provides penalties of ₹10,000 plus ₹100 a day on the company (up to ₹2 lakh) and on the officer in default (up to ₹50,000).
What are the Extract of Board Report and Extract of Auditor's Report forms?
New e-forms introduced by the Companies (Accounts) Second Amendment Rules, 2025 (G.S.R. 357(E), in force from 14 July 2025). Under rule 12(1C), they must be filed along with AOC-4, AOC-4 CFS, AOC-4 XBRL or the NBFC variants, so that key content of the Board's Report and the audit report is captured as structured data.
What new disclosures does the Board's Report need for FY 2025-26?
The number of sexual harassment complaints received during the year, disposed of during the year, and pending for more than 90 days, under rule 8(5)(x); and a statement on compliance with the Maternity Benefit Act, 1961, under the new rule 8(5)(xiii).
Who has to file AOC-4 XBRL instead of AOC-4?
Companies covered by the XBRL Rules, 2015: listed companies and their Indian subsidiaries, companies with paid-up capital of ₹5 crore or more, companies with turnover of ₹100 crore or more, and companies preparing Ind AS financial statements. Banking, insurance, power and NBFCs are excluded.
Does a company with no business still have to file AOC-4?
Yes. The obligation depends on the company existing, not on its trading. A dormant or zero-revenue company still holds its AGM and files AOC-4 and MGT-7 or MGT-7A; the ₹100-a-day late fee applies in the same way.
Is AOC-4 required if the AGM could not be held?
Yes. Under Section 137(2), the signed financial statements are filed within 30 days of the last date on which the AGM should have been held, with a statement of the fact and reasons. The adopted statements are filed after the AGM is eventually held.
ROC compliance for private limited companies
AOC-4 with the new extract forms, MGT-7 and ADT-1, filed alongside the statutory audit — scope and fee confirmed in writing before work begins.
Learn more