Is DIR-3KYC Needed

Hello - I am trying to do DIR-3KYC for our directors for this year 

Director 1 , last DIR-3KYC was done June 29, 2025

Director 2, last DIR-3KYC was done June 19, 2025

Director 3, DIN Issued on March 19, 2026, and DIR-12 for Director Addition done on March 21, 2026

The MCA site shows all three active and DIR-3KYC form shows the KYC Compliance Checkbox greyed out (unable to use). 

I hear DIR-3KYC is required every 3 years now. Can you please help understand of anyone the above needs to do DIR-3KYC this year. Especially for Director 3 as he never filed DIR-3KYC before, I wanted to make sure if anything could be needed.

Much appreciate quick response as time is really short with Sep 30 deadlines.

 

 

 

 

 

Replies (1)
None of the three directors are required to file Form DIR-3 KYC for the year 2026.

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.
No DIR-3 KYC filing is required for any of the three directors in 2026. Directors 1 and 2 are covered under the 3-year compliance cycle following their 2025 submission, while Director 3’s KYC was completed during DIN allotment in March 2026. All three DINs remain fully active on the MCA portal.

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