Is DIR-3KYC Needed

Detailed Analysis by Director

1. Directors 1 & 2 (Filed in June 2025)

• Regulatory Provision: Under the MCA rules (Companies (Appointment and Qualification of Directors) Amendment Rules, effective March 31, 2026), Director KYC compliance has transitioned from an annual mandate to a triennial (3-year) cycle.
• Status & Portal Behavior: Since both directors completed DIR-3 KYC in June 2025 and their personal details (mobile, email, address) remain unchanged, no filing is due in 2026. Their DIN status remains "Approved / Active," which is why the MCA portal automatically greys out the KYC compliance option.

2. Director 3 (DIN Allotted on March 19, 2026)

• Regulatory Provision: When a DIN is newly allotted during a financial year (FY 2025–26), all KYC details (PAN, Aadhaar/Passport, mobile, email, address) are verified and captured at the time of DIN allotment itself (via SPICe+ / eForm DIR-3).
• Filing Exemption: Under MCA Rule 12A, a DIN holder is not required to file DIR-3 KYC in the same financial year in which the DIN was issued. Their 3-year KYC cycle begins from the financial year of allotment (FY 2025–26).
• Status & Portal Behavior: The DIN is automatically marked as "Approved / Active" upon allotment, which is why the DIR-3 KYC checkbox is greyed out for this director as well.

Operational Clarifications

• Greyed-Out Checkbox: This is standard MCA portal functionality indicating that the DIN is currently compliant and no submission is pending.
• Exceptions to the 3-Year Rule: If any director updates their personal details (such as mobile number, email address, or residential address) at any point, an updated DIR-3 KYC Web submission must be filed within 30 days of the change.