Form AOC-4 Filing Guide for FY 2025-26 — Everything Changed on July 14, 2025
If your company's financial year ended on 31 March 2026, you are now in the compliance window for filing Form AOC-4 — India's mandatory financial statement filing with the Registrar of Companies (ROC) under Section 137 of the Companies Act, 2013. But before you open the MCA portal, there is something critical you must know: everything about how AOC-4 is filed changed fundamentally on July 14, 2025.
The MCA completed its full migration from the old V2 portal to the new MCA V3 portal on July 14, 2025, deploying the last batch of 38 company e-forms including the entire AOC-4 family. This was accompanied by two major amendment rules — the Companies (Accounts) Second Amendment Rules, 2025 and the XBRL Amendment Rules, 2025 — that redesigned the form itself, introduced new e‑forms and disclosure requirements, and made PDF attachments of the extract of Board’s Report, extract of Auditor’s Report and (for XBRL filers) signed financial statements mandatory instead of the earlier simpler attachment pattern.
This guide covers everything: what AOC-4 is, who must file, which form variant applies to your company, the due dates for FY 2025-26, every amendment that took effect on July 14, 2025, how to file step-by-step on the new V3 portal, what attachments are mandatory, and what penalties apply for non-compliance.
📋 Quick Summary — AOC-4 Filing for FY 2025-26
Key Numbers at a Glance
What is Form AOC-4? — The Foundation
Form AOC-4 is the prescribed e-form for filing a company's annual financial statements with the ROC (Registrar of Companies). Under Section 137(1) of the Companies Act, 2013, every company must file a copy of its financial statements — including the Balance Sheet, Statement of Profit and Loss, Cash Flow Statement, and Notes — with the ROC within 30 days of the AGM (Annual General Meeting). For One Person Companies (OPCs), the same must be filed within 180 days from the end of the financial year.
💡 Why AOC-4 Matters — Section 137 at a Glance
AOC-4 is not just an administrative form — it is the primary mechanism through which India's corporate financial data becomes part of the public record. Once filed, the financial statements are accessible to investors, lenders, regulators, and the public through MCA21. Non-filing invites penalties, director disqualification, and ultimately the company's strike-off from the register. It is one of the most important annual compliance obligations for every company in India.
The form requires reporting on: the company's financials (with comparative figures), details of the audit committee, auditor information, compliance certifications from the MD/CFO/CS, related party transactions summary, CSR details (if applicable), and — as of July 14, 2025 — secretarial audit qualification disclosures and links to multiple mandatory linked forms.
⚠ What Changed — Major Amendments Effective July 14, 2025
📅 FY 2024-25 Extensions — For Context and Reference
- General Circular No. 06/2025 (October 17, 2025): Extended filing of AOC-4, AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), and all variants for FY 2024-25 to 31 December 2025 without additional fees — due to V3 transition difficulties
- General Circular No. 08/2025 (30 December 2025): Further extended to 31 January 2026 — one additional month for companies still facing transition issues
- For FY 2025-26: No extension has been announced as of June 2026. Companies should file by the standard due dates. File early to avoid portal congestion.
Who Must File AOC-4?
✅ Applicability — All Companies Must File
- Every company registered under the Companies Act, 2013 — whether private or public, listed or unlisted, small company or large
- Foreign companies registered in India under Section 380 must file Form AOC-4 XBRL or the applicable variant
- Dormant companies — must still file AOC-4 annually
- Companies under CIRP or liquidation — can now file AOC-4 by affixing DSC of the Insolvency Resolution Professional (IRP/RP/liquidator) as per V3 changes
- One Person Companies (OPCs) — file separately with different due dates
- Exemption: Companies incorporated during the financial year and yet to hold their first AGM — may claim exemption for their first year in some specific circumstances, but filing is generally required
Due Dates for FY 2025-26 — Mark These on Your Calendar
📅 AGM Due Date — The Critical Trigger for Non-OPC Companies
For most companies, the AOC-4 due date is calculated from the AGM date — not the FY end date. This is why AGM compliance is directly linked to AOC-4 compliance. Companies must hold their AGM by 30 September 2026 (6 months after FY end). If the AGM is held on September 30, 2026, the AOC-4 due date is October 30, 2026 — making October 29, 2026 effectively the last day. If a company delays its AGM, it shifts (and risks) the AOC-4 deadline too. Note: AGM extension is permissible under Section 96 for the first year or in special circumstances, but requires ROC permission.
All Form Variants — Which AOC-4 Should Your Company File?
Standard — All Companies (Standalone)
The base form. Every company files AOC-4 for its standalone financial statements. This is the primary form — all other variants are either alternatives or linked additions to this form.
Consolidated Financial Statements
Required when a company has subsidiaries, associates, or joint ventures and must prepare Consolidated Financial Statements under Section 129(3). As of July 14, 2025, this is now a linked form — filed together with the primary AOC-4, not independently. Triggered automatically when "Yes" is selected for "Whether consolidated FS required" in the primary AOC-4.
XBRL Format — Listed + Large Companies
Mandatory for: (a) all companies listed on any recognised stock exchange, (b) companies with paid-up share capital of ₹5 crore or more, (c) companies with annual turnover of ₹100 crore or more. As of G.S.R. 371(E), now also requires a signed PDF of financial statements in addition to XBRL data.
NBFCs Following Ind AS
Filed by Non-Banking Financial Companies (NBFCs) that have adopted Indian Accounting Standards (Ind AS) — primarily larger NBFCs and systemically important NBFCs. Separate from the standard AOC-4 due to different financial statement formats under Ind AS.
Consolidated FS — NBFCs (Ind AS)
For NBFCs following Ind AS that also have subsidiaries/associates/JVs requiring consolidated financial statements. The CFS variant for the NBFC Ind AS category.
The Linked Forms System in MCA V3 — What It Is and Why It Matters
The most fundamental change in the July 14, 2025 overhaul is the introduction of the Linked Forms System on MCA V3. Understanding this is essential before you begin any filing.
🔗 What Are Linked Forms?
In the old V2 system, the AOC-4 was a standalone form. If the company also needed to file CSR-2 or CFS, those were separate, independent filings. In V3, some forms are now "linked" — meaning they are mandatory annexures to the primary AOC-4 that must be submitted as part of the same filing workflow. You cannot submit the primary AOC-4 without also completing the applicable linked forms in the same session.
⚠ Critical Point — e-AOC-1 Now Requires Professional Certification
A significant upgrade from the old regime: Form AOC-1 (statement containing salient features of subsidiaries/associates/JVs) has been converted from a manual form to an e-Form (e-AOC-1). It now requires certification by a practising professional (Practising Company Secretary or Chartered Accountant). This means holding companies with subsidiaries must ensure their PCS or PCA certifies e-AOC-1 as part of the AOC-4 filing package.
How to File AOC-4 on MCA V3 — Step-by-Step Process
Before You Start — Pre-Filing Preparation
📄 Documents to Keep Ready Before Opening the Portal
- Signed financial statements (Balance Sheet, P&L, Cash Flow Statement, Notes to Accounts) — authenticated under Section 134 with DSC of MD/CFO/CS + 2 directors
- Board's Report (signed by MD or Chairperson) — including Maternity Benefit Act compliance declaration (new requirement)
- Auditor's Report — both standalone and consolidated (if applicable)
- XBRL data file (XML) — if filing AOC-4 XBRL (prepared using MCA-approved XBRL software)
- CSR Report details — if Section 135 applies (to fill CSR-2 linked form)
- AOC-1 data — if company has subsidiaries/associates/JVs
- AOC-2 details — related party transactions (if applicable)
- Valid DSC of authorised signatory (MD/CEO/Manager) + Company Secretary/Director
- DSC of Practising Professional (PCS/PCA) — for professional certification of e-AOC-1 and other forms requiring it
- CIN of the company, PAN, and other master data
Log In to MCA V3 at www.mca.gov.in
Log in with your V3 registered credentials. If you registered on V2, use the credentials sent to your email at the time of V3 registration (V2 IDs were migrated). Go to MCA Services → Company e-Filing. Ensure your DSC token is inserted and the MCA V3 DSC plugin/utility is installed in your browser.
Navigate to Annual Filing → Select AOC-4 Variant
Under Company e-Filing, select the annual filing section. Choose the appropriate form — AOC-4, AOC-4 XBRL, or AOC-4 NBFC (Ind AS) — based on your company's applicability. Click "Start New Filing." The system will open the form in your browser (online mode) or offer an Excel download (offline mode).
Choose Filing Mode — Online or Offline (Excel)
V3 offers two modes: Online mode — fill the form directly in browser, supports real-time auto-population; Offline mode — download the form as an Excel workbook, fill data in Excel, then upload back to V3. For large forms with extensive financial data, the offline Excel mode may be more convenient. CSR-2 linked form tables are also downloadable in Excel to save time in data entry.
Enter CIN — Auto-Population of Master Data
Enter the company's CIN (Corporate Identity Number). The V3 portal auto-populates: company name, registered address, date of incorporation, category, sub-category, and other master data. Review the auto-populated data carefully and correct any discrepancies. The new V3 form also auto-prefills previous year's financial figures from the last filed AOC-4 — verify these carefully and provide mandatory explanations for any modifications.
Enter Financial Statement Data — Balance Sheet, P&L, Cash Flow
Fill in the current year financial data: equity and liabilities, assets, revenue, expenses, profit/loss figures. The form has structured fields for each line item. Comparative figures (previous year) are pre-filled — verify and correct if they differ from the audited comparative figures. All amounts in Indian Rupees (round to nearest rupee). Enter details of auditors, audit committee, directors present at signing, etc.
Fill the New Secretarial Audit Qualifications Table
The revised AOC-4 form includes a new table for capturing Secretarial Audit qualifications, adverse remarks, or observations from the Secretarial Audit Report (if applicable). This is a new transparency requirement — companies for which Secretarial Audit is mandatory under Section 204 must fill this table. Ensure consistency between what is disclosed here and what is in the Board's Report.
Complete All Mandatory Linked Forms
This is the most critical new step. After the primary form data, the portal will prompt you to complete linked forms. The system automatically determines which linked forms apply based on your form selections. You must complete: (a) Extract of Board Report — enter key Board's Report content, (b) Extract of Auditor's Report Standalone, (c) Extract of Auditor's Report Consolidated (if CFS applicable), (d) AOC-4 CFS (if applicable), (e) CSR-2 (if Section 135 applies). All linked forms must be completed before the primary form can be submitted.
Upload Mandatory PDF Attachments
Attach the required documents as per the revised rules. See the Attachments Checklist section below for the complete list. For XBRL filers, also upload the XBRL XML data file. All PDFs must be duly authenticated under Section 134 before uploading — i.e., signed by the authorised directors, CEO/MD, CFO, and CS with their DSCs before creating the PDF.
Certify Forms Requiring Professional Sign-off
e-AOC-1 requires certification by a Practising Company Secretary (PCS) or Chartered Accountant. The certifying professional must affix their DSC. For companies where AOC-4 itself requires professional certification (certain categories), the PCS/CA must also sign the primary form. The Compliance Certificate in the form must be signed by the Company Secretary of the company (if one is appointed) or the certifying practitioner.
Affix DSC of Authorised Signatory
The primary AOC-4 must be signed by: (a) the Managing Director or in his absence any director, (b) the Chief Financial Officer, and (c) the Company Secretary (if appointed). Affix the DSC of each required signatory. If signatories are in different locations, they can sign in sequence — V3 supports multi-party DSC signing. Ensure all DSCs are valid (not expired), Class 2 or Class 3, and registered with MCA.
Calculate Fee and Pay Online
The portal automatically calculates the applicable government fee based on authorised share capital. Review the calculated fee. Pay via credit/debit card, net banking, or UPI through the MCA payment gateway. An e-receipt is generated — save this as proof of payment. See fee structure in the next section.
Submit and Save Your SRN
Click "Submit." The portal generates a unique Service Request Number (SRN) — this is your proof of filing. Save the SRN immediately. The ROC/CRC processes the filing (typically within a few working days). Track status on the MCA portal using your SRN. You will receive an acknowledgement email at your registered email ID once processed. The filing is complete only when the ROC marks it as "Approved."
Mandatory Attachments Checklist — V3 Revised Requirements
Fee Structure and Late Penalty Calculator
📅 Late Filing Penalty (Section 403)
₹100/dayAdditional fee of ₹100 per day from the due date till the actual date of filing. No maximum cap — it compounds indefinitely. Example: filing 200 days late = ₹20,000 additional fee on top of normal fee. Applies to AOC-4, AOC-4 XBRL, AOC-4 CFS, and all variants.
⚠ Company & Officer Penalty (Section 137)
₹1L–₹5LIf AOC-4 is not filed: Company — fine of ₹1,000 per day (up to ₹10 lakh); MD/CFO — imprisonment up to 6 months OR fine of ₹1 lakh to ₹5 lakh. Adjudication proceedings separately from additional fees. Actual example: ₹3.50 lakh penalty imposed on a company + directors for non-filing.
⚠ Director Disqualification — Section 164(2)
A director of a company that has failed to file AOC-4 for any continuous 3-year period becomes disqualified from being reappointed as director of that company, and cannot be appointed as director in any other company for a period of 5 years. MCA periodically publishes lists of disqualified directors. This has been actively enforced — hundreds of directors have been disqualified in past enforcement drives.
📈 Calculate Your Late Filing Penalty Instantly
Use the CorpLawUpdates Penalty Calculator to calculate the exact additional fee your company owes for late AOC-4 filing — based on your specific due date and actual filing date.
Common Issues and How to Resolve Them
🔗 Filing AOC-4? Don't Forget MGT-7 / MGT-7A
AOC-4 and MGT-7/MGT-7A are India's two core annual compliance filings. Both are due within 60 days of AGM (MGT-7 due date: November 28, 2026 for FY 2025-26). Read the complete MGT-7 filing guide for FY 2025-26 for due dates, form variants, V3 changes, and small company applicability.
Frequently Asked Questions — AOC-4 FY 2025-26
📚 Basics
The changes notified by the Companies (Accounts) Second Amendment Rules, 2025 (G.S.R. 357(E)) and the revised XBRL rules are substantial and apply from 14 July 2025 onwards:
- Revised e‑forms: AOC‑4, AOC‑4 CFS, AOC‑4 NBFC (Ind AS), AOC‑4 CFS NBFC (Ind AS), CSR‑2, e‑Form AOC‑1 and e‑Form AOC‑2 have all been updated for MCA V3 with new fields and validations.
- Mandatory attachments: A new sub‑rule under Rule 12 requires companies to upload PDF attachments along with the applicable AOC‑4 forms: (a) extract of the Board’s Report, (b) extract of the Auditor’s Report (Standalone and, where applicable, Consolidated), and (c) in the case of XBRL filers, duly signed financial statements in PDF in addition to the XBRL file.
- CSR‑2 as a linked filing: For financial years 2024‑25 onwards, Form CSR‑2 is filed as a linked form with AOC‑4 / AOC‑4 NBFC / AOC‑4 XBRL wherever Section 135 applies, instead of as a completely independent form on V3.
- e‑Form AOC‑1 and AOC‑2: References to “Form AOC‑1” and “Form AOC‑2” in the Accounts Rules are replaced with “e‑Form AOC‑1” and “e‑Form AOC‑2”, and these now require electronic filing and professional certification on V3.
- Enhanced Board’s Report disclosures: The Board’s Report must now include quantitative data on POSH complaints and a formal compliance statement with the Maternity Benefit Act, 1961, which is captured through the extract of Board’s Report that accompanies AOC‑4 filings.
Do note that as per recent MCA FAQs and practitioner updates, for the AOC‑4 XBRL form only CSR‑2 operates as a linked form for FY 2024‑25 onwards; AOC‑1, AOC‑2 and the extracts of Board’s/Auditor’s Reports are filed as separate e‑forms or mandatory attachments, not as “linked forms” for every company.
📄 V3 Specific
There are two layers of consequences — statutory penalty under Section 137 and additional fee under Section 403 / Fees Rules:
- Penalty under Section 137(3) (Companies Act, 2013):
If a company fails to file its financial statements within the prescribed time:
- Company: penalty of ₹10,000 plus ₹100 per day for each day during which the failure continues, capped at ₹10,00,000.
- Managing Director / CFO / other officers in default: penalty of ₹1,00,000 plus ₹100 per day after the first day, capped at ₹5,00,000 per person.
- Additional fee under Section 403 and the Companies (Registration Offices and Fees) Rules, 2014: For forms under Sections 92 and 137 (including AOC‑4, AOC‑4 XBRL, AOC‑4 CFS, MGT‑7), an additional fee of ₹100 per day of delay is payable from the original due date until the actual filing date, with no upper cap on this additional fee.
- Other consequences: continued non‑filing for three consecutive financial years can lead to director disqualification under Section 164(2), and persistent non‑compliance may form grounds for the company being struck off under Section 248.
Conclusion
Filing AOC-4 for FY 2025-26 is a substantially different exercise from what it was just two years ago. The complete shift to MCA V3, the introduction of the linked forms system, the elimination of PDF attachments for Board's and Auditor's Reports, the new XBRL signed PDF requirement, the professional certification for e-AOC-1 and e-AOC-2, and the new Maternity Benefit Act disclosure — all of these represent a fundamental modernisation of how India's corporate financial reporting works.
The key message for companies and their compliance professionals is: start early. The V3 portal is stable but complex. Gathering all required data for linked forms, ensuring all signatories' DSCs are valid, preparing the XBRL file (if applicable), and completing the entire linked form chain takes significantly more time than the old V2 PDF attachment approach. Do not leave this for October 2026. Start your preparation the moment your audited accounts are finalised after the AGM.
