Quick Answer
What ICSI Asked For
ICSI's representation (ref. G&CL: MCA: OCT:01/2026, dated 9 October 2026, addressed to the Secretary, Ministry of Corporate Affairs) seeks a one-time relaxation for the following forms, up to 31 December 2026, without levy of additional fees:
Why ICSI Asked
- MCA-21 V3 portal trouble — downtime, slow responses, session timeouts, login problems, incorrect pre-filled data, DSC association failures, validation errors and payment/SRN difficulties.
- Heavier forms — the revised AOC-4 and MGT-7 demand far more granular data and disclosures; XBRL tagging and reconciliation add preparation time.
- Precedent — CBDT Circular No. 07/2026 dated 28 September 2026 extended the tax audit report deadline to 21 October 2026 and ITR for audit cases (AY 2026-27) to 21 November 2026.
What MCA Has Actually Done — Verified 15 Oct 2026
MCA's official General Circulars listing was checked on 15 October 2026. The latest General Circular is No. 04/2026 dated 31-08-2026 (Companies Compliance Facilitation Scheme, 2026 — a backlog-clearance window that closed 15-09-2026, not an FY 2025-26 extension). No circular extending FY 2025-26 annual filing deadlines exists.
Your Deadlines Haven't Moved
For the common case of an AGM held on 30 September 2026:
What Waiting Costs
Additional fees under Rule 12 of the Companies (Registration Offices and Fees) Rules, 2014 run at Rs 100 per day, per form — with no upper cap for delays beyond Sections 92(4) and 137(1). A 30-day delay on two forms is Rs 6,000; the meter keeps running indefinitely. Only a numbered MCA General Circular can waive these fees — a representation cannot.
What To Do Now
- File ADT-1 immediately if your AGM was on 30 September — it fell due on 15 October 2026.
- Treat 30 October (AOC-4) and 29 November (MGT-7) as hard dates until MCA says otherwise in a numbered circular.
- Don't bank on the extension. Early filers lose nothing if it comes; late filers pay Rs 100/day/form if it doesn't.
Frequently Asked Questions
Has MCA extended the AOC-4 / MGT-7 due dates for FY 2025-26?
No. As verified on MCA's official circulars listing on 15 October 2026, no General Circular extending FY 2025-26 annual filing deadlines has been issued.
Does ICSI's letter itself extend the deadline?
No. A representation is a request, not a legal instrument. Only a numbered MCA General Circular can extend a statutory deadline or waive additional fees.
What is the late filing fee?
Rs 100 per day per form under the Companies (Registration Offices and Fees) Rules, 2014, with no maximum cap.
Source Note
ICSI representation: G&CL: MCA: OCT:01/2026 dated 9 October 2026 (as reported in professional press).
Statutory basis: Sections 92(4), 137(1), 139(1), Companies Act, 2013; Rule 12, Companies (Registration Offices and Fees) Rules, 2014.
For information only; not legal advice. Verify dates against your company's AGM.
