Annual ROC Compliance After AGM: A Practical Guide to AOC-4, MGT-7, ADT-1 and MGT-14

For a company with a 31 March 2026 year-end, the AGM was due by 30 September. After the AGM, four filings follow, and every clock runs from the actual AGM date, not from 30 September.

The post-AGM clock (example: AGM on 30 September 2026)

If your AGM was earlier, recalculate. An AGM on 14 August makes AOC-4 due on 13 September.

Form by form

• AOC-4: It must agree with the signed financial statements, so check the data entered in the form itself, not just the uploaded PDF. Test XBRL and consolidation applicability afresh.
• MGT-7 / MGT-7A: Data should agree with the register of members, share capital records and MCA master data. MGT-7A is the abridged return for OPCs and small companies, and MGT-8 certification applies above specified thresholds (₹10 crore paid-up capital or ₹50 crore turnover).
• ADT-1: This is not an annual form for everyone. It is filed when an auditor is appointed or re-appointed, typically once every five years or on a change.
• MGT-14: Every special resolution, whether private or public, needs it within 30 days. Ordinary resolutions at the AGM, such as adopting accounts and appointing auditors, generally do not, because AOC-4 and ADT-1 cover them. Whether a private company must also file for the board resolution approving the financial statements is a point on which commentary is divided. Many rely on the 2015 private-company exemption (GSR 464(E)), but check before deciding.

Two 2025-26 changes

1. Small company thresholds rose from 1 December 2025 to ₹10 crore paid-up capital and ₹100 crore turnover. Re-test whether MGT-7A is now available. Holding and subsidiary companies and Section 8 companies are still excluded.
2. Director KYC moved from annual to a three-year cycle, per rules effective 31 March 2026. Don't carry a "KYC by 30 September" line into the checklist automatically.

What default costs

• An additional fee of ₹100 per day, per form for delayed AOC-4 and MGT-7. Each form accrues separately.
• Separate statutory penalties under ss. 92 and 137. Paying the additional fee does not by itself end the exposure.
• Director disqualification under s. 164(2) after prolonged default.
• The one-time Companies Compliance Facilitation Scheme, 2026 has ended, so legacy defaults carry full fees.

Practical checklist

1. Fix the AGM date and calculate all four dates before the meeting.
2. Reconcile share capital, borrowings and related parties before filing.
3. Confirm small-company status, XBRL and MGT-8 applicability.
4. File ADT-1 and MGT-14 first, then AOC-4, then MGT-7.
5. Keep the AGM minutes, the resolutions and the filed forms consistent with each other.

Bottom line: AOC-4 for a 30 September AGM is due in ten days. Treat the AGM as the start of the filing clock, not the end of the compliance cycle.