MCA Compliance Relief 2026: DPT-3 Extension, CCFS Deadline & Complete ROC Filing Calendar

The fire at the MCA Data Centre on 5 June 2026 forced an unscheduled switchover to the Disaster Recovery site and left several MCA21 services partially unavailable for days - right in the middle of the busiest pre-deadline filing window of the year. The Ministry responded with a cluster of relief measures, and a company secretary or director's question now is a simple one: what do I still have to file, by when, and where do the extensions actually apply?

This is the consolidated answer - every relief measure in one place, the full July–September 2026 ROC calendar, and the personal-liability consequences of getting it wrong.

The post-fire relief measures, in one place

Three distinct reliefs are in play. They cover different forms and have different deadlines - do not assume one extension covers everything.

1. DPT-3 extended to 31 July 2026 (automatic fee waiver)

Via General Circular No. 02/2026 dated 19 June 2026 , the due date for filing Form DPT-3 (Return of Deposits) for FY 2025-26 has been extended from 30 June to 31 July 2026 without additional fees , citing capacity-enhancement and restoration work at the Data Centre after the fire. This is a fee relaxation only - the statutory obligation is unchanged, no Helpdesk request is needed, and filings after 31 July attract normal additional fees. A common trap: many directors believe DPT-3 applies only if the company took public deposits. It also captures outstanding loans from directors, shareholders, banks, group entities and inter-corporate borrowings as on 31 March 2026 - so most companies need to file it.

2. Name reservation and e-form resubmission relief (Helpdesk-driven, act by 30 June)

For reservations and resubmissions disrupted by the outage:

• Company/LLP name reservations expiring 21–30 June 2026 are automatically extended to 10 July 2026 - no action needed.
• Name reservations that expired between 5 and 20 June 2026 can be extended to 10 July 2026, but you must raise a request with the MCA Helpdesk before 30 June 2026 .
• E-forms with resubmission dates falling 21–30 June 2026 remain valid until 10 July 2026; those due 5–20 June 2026 can be extended to 10 July via a Helpdesk request before 30 June.
• E-forms cancelled for non-resubmission during this period may be reopened on request and verification, and made available for resubmission until 10 July 2026.

If any of your reservations or pending resubmissions fall in the 5–20 June band, the 30 June Helpdesk cut-off is the most time-critical item on this entire list.

3. CCFS-2026 amnesty window closes 15 July 2026

Separately from the fire reliefs, the Companies Compliance Facilitation Scheme, 2026 (General Circular No. 01/2026 dated 24 February 2026) is still running and closes on 15 July 2026 . Under it, companies can clear pending annual filings - AOC-4 (all variants), MGT-7/MGT-7A and ADT-1 - by paying only 10% of the additional fees (roughly a 90% waiver), with immunity from penalty under Sections 92 and 137 where filed before, or within 30 days of, any notice. Inactive companies can opt for dormant status via MSC-1 at 50% of the normal fee, or strike-off via STK-2 at 25%. The standard ₹100/day-per-form additional fee (no upper cap) resumes from 16 July, and the ROC has been directed to move against remaining defaulters. CSR-2 is now filed as part of AOC-4 on the V3 portal. Note that non-conduct of the AGM (Section 96) is not covered by CCFS and must be compounded separately.

The July-September 2026 ROC compliance calendar

An important clarification on AOC-4 and MGT-7

For a normal company with a 31 March year-end, AOC-4 and MGT-7 are not July–September filings - they are triggered by the AGM and fall due in October and November respectively. What July–September actually decides is the AGM: hold it by 30 September, and the 30-day (AOC-4) and 60-day (MGT-7) clocks start ticking from that date. The only annual financial-statement filing genuinely due inside this quarter is the OPC's AOC-4 (27 September), since OPCs have no AGM. Plan the quarter around the AGM, and the autumn filings fall into place.

DIR-3 KYC is no longer an annual September filing. This is the trap most compliance calendars still get wrong. Under the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025 (Notification G.S.R. 943(E) dated 31 December 2025, effective 31 March 2026 ), the substituted Rule 12A makes Director KYC a triennial obligation - filed on the unified Form DIR-3 KYC Web on or before 30 June of the year immediately following every third consecutive financial year. Directors who completed their KYC through FY 2025-26 have their next routine filing due 30 June 2028.

In between, only two things trigger a filing: a change in mobile number, email or residential address (file within 30 days), or reactivation of a deactivated DIN. So for most directors there is no DIR-3 KYC item in this quarter at all - the old 30 September deadline no longer applies.

A practical note on jurisdiction: following the ROC reorganisation effective 16 February 2026 (for example, ROC Delhi split into Delhi I/II and Haryana; ROC Mumbai into Mumbai I/II and Nagpur), confirm the ROC your company is now mapped to before filing.

5 compliance failures that put directors at risk of disqualification

ROC non-compliance is not just a company-level penalty problem. Under Section 164(2)(a) of the Companies Act, 2013 , if a company fails to file its financial statements or annual returns for any continuous period of three financial years , every director of that company is disqualified for five years - the DIN is deactivated and, under Section 167 , the director must vacate office in every company they sit on, except the defaulting one. These are the five failures that lead there:

1. Letting AOC-4 or MGT-7 lapse for three consecutive years. This is the direct Section 164(2)(a) trigger. It is automatic on the ROC's records - no court order is required - and it follows the director across their entire portfolio, not just the defaulting company.
2. Assuming a dormant, nil or non-operational company is exempt. It is not. Even a zero-revenue company must file AOC-4 with nil financial statements and MGT-7/MGT-7A with nil activity. The obligation tracks the company's existence , not its turnover.
3. Not breaking the three-year chain in time. The three years must be continuous - filing even one pending year (even late) resets the clock and stops disqualification from triggering. CCFS-2026, closing 15 July 2026, is the cheapest way to do exactly that at 10% of additional fees. Miss the window, and you both lose the discount and stay exposed.
4. Ignoring DIR-3 KYC. Non-filing of DIR-3 KYC does not by itself cause Section 164(2) disqualification - but it deactivates the DIN ("Deactivated due to non-filing of KYC"), which blocks the very AOC-4/MGT-7 filings you need to make to avoid disqualification. It is a ₹5,000 reactivation cost and an avoidable obstacle.
5. Continuing to act after disqualification - or appointing a director without checking DIN status. Acting as a director after office has been vacated under Section 167 is a criminal offence under Section 167(2), carrying imprisonment up to one year or a fine of ₹1–5 lakh. Equally, before filing DIR-12 to appoint an incoming director, their DIN status must be verified on the MCA portal - a disqualified DIN will cause the form to be rejected, and the DIR-8 declaration now specifically requires disclosure of any disqualification.

One nuance worth stating plainly for clients already in default: regularising filings (including under CCFS-2026) prevents a disqualification from triggering and is essential housekeeping, but the Companies Act does not provide a direct statutory route to reverse a disqualification that has already taken effect. Once triggered, relief generally lies through NCLT restoration under Section 252 (where the company was struck off), a High Court writ, or automatic de-flagging after the five-year period. Prevention is dramatically cheaper than cure.

FAQ

1. Has the DPT-3 due date really moved, and do I need to apply for it?

Yes - DPT-3 for FY 2025-26 can be filed without additional fees up to 31 July 2026 under General Circular 02/2026. No application or Helpdesk request is needed; just file by 31 July. After that, normal additional fees apply.

2. My company's name reservation expired during the outage. What do I do?

If it expired 21–30 June 2026, it is automatically valid to 10 July 2026. If it expired 5–20 June 2026, raise a request with the MCA Helpdesk before 30 June 2026 to extend it to 10 July. Cancelled e-forms can also be reopened on request.

3. Did the CCFS-2026 deadline get extended because of the fire?

As matters stand, CCFS-2026 closes on 15 July 2026. Only the DPT-3 date and the name/resubmission validity were extended by the fire-related reliefs. Watch the MCA portal for any further notification, but plan to file by 15 July.

4. Are AOC-4 and MGT-7 due in this quarter?

No - for a 31 March year-end company they follow the AGM and fall due around 30 October (AOC-4) and 29 November (MGT-7). The July–September task is to hold the AGM by 30 September, which starts those clocks. The exception is an OPC's AOC-4, due 27 September.

5. Will a single missed filing disqualify me as a director?

Section 164(2)(a) requires the company to miss its financial statements or annual returns for three continuous financial years. One year's default does not disqualify - but it starts a chain, and a director who lets it run to three years is disqualified for five years across all companies. File even one pending year to reset it.

6. Does missing DIR-3 KYC disqualify me, and isn't it due in September?

Two things. First, DIR-3 KYC is now a triennial filing due 30 June (not the old annual 30 September), following the December 2025 amendment to Rule 12A - most currently-compliant directors are next due 30 June 2028. Second, missing it does not cause Section 164(2) disqualification; it deactivates the DIN until you file (with a ₹5,000 fee), which is a separate consequence. But a deactivated DIN prevents you from making the AOC-4/MGT-7 filings that keep you out of disqualification - so it should not be ignored.

This article consolidates MCA General Circulars 01/2026 and 02/2026, the related name-reservation/resubmission relief, and the relevant provisions of the Companies Act, 2013, as available at the time of writing. Dates and relief measures may be revised by subsequent MCA circulars; verify against the official MCA portal and the specific circular before relying on any date for a filing. 

Authored by CA Sundram Gupta, Patron Accounting LLP - a chartered accountancy and company secretarial firm handling ROC/MCA annual filings, DPT-3, CCFS-2026 regularisation and director-compliance matters for companies across Pune, Mumbai, Delhi and Gurugram.