KEY CHANGE
Yes — the extension is granted. MCA's General Circular No. 05/2026, dated 24 October 2026, lets companies file their FY 2025-26 financial statements in AOC-4 and its variants up to 31 December 2026, and their annual returns in MGT-7/MGT-7A up to 31 January 2027, in both cases without additional fees. AGM timelines are not extended, and ADT-1 and DIR-12 are not covered by this circular.
What MCA has granted
The Ministry of Corporate Affairs issued General Circular No. 05/2026 on 24 October 2026 (File No. Policy-17/111/2022-CL-V-MCA), signed by Nupur Aishwarya, Deputy Director (Policy). The circular records that the Ministry received representations from various stakeholders seeking more time for annual statutory filings under the Companies Act, 2013, for the financial year 2025-26 — and it grants that relief in two parts.
First, companies may file their financial statements in e-forms AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) for FY 2025-26 up to 31 December 2026. Second, companies may file their annual returns in e-forms MGT-7 and MGT-7A for FY 2025-26 up to 31 January 2027. Both windows operate without payment of additional fees — the Rs 100-per-day additional fee that normally runs from the statutory due date does not apply to filings made within these extended windows.
The circular also directs MCA's e-Governance section and web content officer to place it on the MCA website, which is the usual route by which these circulars reach the public record.
The new dates at a glance
Remember that these statutory dates assume an AGM held on 30 September 2026, the last permitted day. AOC-4 is due within 30 days of the AGM and MGT-7 within 60 days, so a company whose AGM was held earlier has earlier statutory dates — but the extended dates in the circular are fixed calendar dates that apply regardless of when the AGM was held.
What did NOT change — read this before you relax
The circular contains three limits that are easy to miss in the celebrations, and each of them matters.
1. AGM timelines are not extended. Paragraph 3 of the circular states this expressly: it "shall not be construed as conferring any extension of statutory time for holding of AGMs by the companies under the Act", and companies that did not adhere to the statutory AGM timelines remain liable under the relevant provisions. This relief waives additional fees on filings; it does not forgive a late AGM.
2. ADT-1 and DIR-12 are not covered. ICSI's representation of 9 October 2026 had asked for ADT-1 (auditor appointment) and DIR-12 (director changes) to be included in the relaxation. The circular does not mention them. ADT-1, which was due within 15 days of the AGM — 15 October 2026 for a 30 September AGM — therefore continues to attract additional fees of Rs 100 per day. Do not assume it is covered.
3. The window is finite. Paragraph 4 provides that filings made after the currency of this circular attract all fees, including additional fees, under the Companies (Registration Offices and Fees) Rules, 2014, computed from the date the filing was actually due. In plain terms: file AOC-4 after 31 December 2026, or MGT-7 after 31 January 2027, and the additional fee clock runs from the original statutory date, not from the extended date. The extension pauses the fee; it does not reset it.
The circular is also silent on additional fees already paid before its issue. It contains no refund provision, so companies that already paid late fees for these forms should not assume a refund follows — that point is not addressed in the circular.
Why MCA granted this — and why it looks familiar
The trigger was ICSI's representation (ref. G&CL: MCA: OCT:01/2026, dated 9 October 2026), which asked MCA to let annual e-forms be filed up to 31 December 2026 without additional fees. ICSI pointed to persistent MCA-21 V3 portal problems — downtime, slow responses, session timeouts, login and DSC-association difficulties, validation errors and payment problems — and to the heavier disclosure load in the revised AOC-4 and MGT-7 forms. It also pointed to CBDT's Circular No. 07/2026 of 28 September 2026, which had already moved income-tax audit and return deadlines for the same practical reasons.
MCA's answer goes slightly further than ICSI asked in one respect: ICSI sought 31 December 2026 for everything, but the circular gives MGT-7/MGT-7A until 31 January 2027 — a full extra month for annual returns, matching the statutory 30/60-day gap between the two filings.
The pattern is also familiar from last year. For FY 2024-25, MCA issued General Circular No. 06/2025 on 17 October 2025 allowing annual filings till 31 December 2025 without additional fees, and then General Circular No. 08/2025 on 30 December 2025 extending the window to 31 January 2026. Both of those circulars carry the same file number as this year's — Policy-17/111/2022-CL-V-MCA — which is the Ministry's standing file for annual-filing relief. This year's circular compresses last year's two steps into one, with the split dates built in from the start.
What companies should do now
Use the window, do not waste it. The extension removes the additional-fee penalty, not the filing obligation. Financial statements still need board approval, auditor sign-off and, where applicable, XBRL tagging — all of which take time. Companies that treat 31 December as the new "last day" and start work in late December will repeat exactly the crunch this circular was issued to relieve.
File ADT-1 separately and immediately if it is pending. It is outside this circular, and every day of delay adds Rs 100. Check its status before assuming the annual filing set is complete.
Keep portal evidence. If the MCA-21 portal disrupts a filing attempt, preserve dated screenshots, SRN details and helpdesk references. The circular's relief is date-based and does not depend on proving portal failure, but evidence remains useful for any later dispute about when a filing was attempted.
Do not defer the AGM. Nothing in this circular extends AGM timelines. A company that has not yet held its AGM for FY 2025-26 is already outside the statutory window, and this circular does not cure that.
Small companies and OPCs. The circular lists the AOC-4 and MGT-7/MGT-7A forms generally and carves out no class of company. MGT-7A — the annual return form for small companies and OPCs — is expressly included in the 31 January 2027 window.
Frequently asked questions
Is the AGM deadline also extended to December or January?
No. The circular expressly excludes AGM timelines. Only the filing windows for AOC-4 and MGT-7/MGT-7A are extended, and only the additional fee is waived within them.
Does the extension cover ADT-1?
No. ADT-1 is not mentioned in General Circular No. 05/2026, even though ICSI's representation asked for it. ADT-1 continues to attract additional fees from its statutory due date.
I already paid additional fees for AOC-4 before this circular. Will MCA refund them?
The circular does not address refunds. It waives additional fees for filings made within the extended windows; it says nothing about fees already paid. Treat a refund as not available unless MCA says otherwise separately.
What happens if I file AOC-4 on 2 January 2027?
You miss the extended window. Under paragraph 4, the filing then attracts all fees including additional fees computed from the original statutory due date (30 October 2026 for a 30 September AGM) — not from 31 December.
Is this the same relief as last year?
Similar, but structured differently. Last year MCA granted relief in two circulars (to 31 December 2025, then to 31 January 2026). This year a single circular grants AOC-4 till 31 December 2026 and MGT-7/MGT-7A till 31 January 2027.
Does the extension apply if my AGM was held before 30 September?
Yes, in the sense that matters: the extended dates are fixed calendar dates (31 December 2026 and 31 January 2027), so any company filing within them pays no additional fees regardless of its AGM date. Your statutory dates were earlier, but the relief window is the same.
Sources
Ministry of Corporate Affairs, General Circular No. 05/2026 dated 24 October 2026 (File No. Policy-17/111/2022-CL-V-MCA) — "Relaxation of additional fees and extension of time for filing of Financial Statements and Annual Returns under the Companies Act, 2013 - reg.". The circular directs MCA's e-Governance section to place it on the MCA website (mca.gov.in). ICSI representation G&CL: MCA: OCT:01/2026 dated 9 October 2026, as reported in professional press. Prior-year comparators: MCA General Circular No. 06/2025 dated 17 October 2025 and No. 08/2025 dated 30 December 2025.
This article was updated on 24 October 2026 to record the extension. Our earlier article tracking the no-extension position stands superseded on the extension question by this circular; the statutory framework it describes (30/60-day clocks, Rs 100-per-day additional fee, AGM timelines) is unchanged.
