Does General Circular No. 05/2026 Cover Other MCA Forms?
No blanket relief has been provided for every MCA e-form.
The MCA AOC-4 and MGT-7 Due Date Extension specifically names:
- AOC-4
- AOC-4 (CFS)
- AOC-4 (XBRL)
- AOC-4 NBFC (Ind AS)
- AOC-4 CFS NBFC (Ind AS)
- MGT-7
- MGT-7A
Forms such as ADT-1, MGT-14 or DIR-3 KYC are not listed in General Circular No. 05/2026. Any relaxation for another form should be checked separately under the relevant MCA notification, circular or applicable rule.
What Should Companies Check Before Using the MCA Relaxation?
Before relying on the MCA AOC-4 and MGT-7 Due Date Extension, a company should confirm that its filing relates to FY 2025-26 and that the relevant form is specifically covered by the circular.
The company should also verify its original statutory filing date, applicable annual return form and AGM position, where an AGM is required.
For OPCs, Ebizfiling also provides an OPC annual filing service for applicable annual compliance requirements.
How Can Ebizfiling Help With AOC-4 and MGT-7 Filing?
The MCA AOC-4 and MGT-7 Due Date Extension gives more time for specified filings, but the correct form and underlying compliance position still need to be checked.
Ebizfiling can assist with reviewing the applicable AOC-4 form, MGT-7 or MGT-7A applicability, supporting company information, annual ROC filing requirements and delayed filing situations based on the documents provided.
Ebizfiling’s role is limited to professional compliance and filing assistance. Acceptance of filings, regulatory action and statutory consequences remain subject to MCA or the jurisdictional Registrar of Companies.
Want to use the MCA relaxation before it expires? Connect with Ebizfiling for AOC-4, MGT-7 or MGT-7A filing assistance for FY 2025-26.
Conclusion
The MCA AOC-4 and MGT-7 Due Date Extension allows specified FY 2025-26 annual filings to be completed without additional fees within the prescribed relaxation period. AOC-4 forms covered by the circular can be filed up to 31 December 2026, while MGT-7 and MGT-7A can be filed up to 31 January 2027.
The relaxation does not extend applicable AGM timelines, and filings made after the relaxation period may attract additional fees calculated from their original statutory due dates.
Frequently Asked Questions
1. Does the MCA filing relaxation change the original statutory due date under the Companies Act?
No. The relaxation only allows specified forms to be filed without additional fees during the permitted period. The original statutory due date under the Companies Act continues to remain relevant for determining compliance and any later additional fee.
2. Can a company use the filing relaxation if its AGM was not held within the statutory timeline?
Yes, the filing relaxation may still apply to the specified annual forms, but it does not regularise the AGM default. AGM compliance and annual filing compliance must be examined separately.
3. How is AOC-4 filing treated where no AGM was held?
Where no AGM is held, Section 137 requires the financial statements to be filed based on the date on which the AGM should have been held, along with the prescribed explanation for not holding the AGM. The filing relaxation does not change this statutory basis.
4. How is MGT-7 filing treated where no AGM was held?
Under Section 92, where no AGM is held, the annual return filing timeline is linked to the date on which the AGM should have been held. The relaxation provides fee relief but does not alter this underlying statutory mechanism.
5. Does filing within the relaxed period remove liability for earlier non-compliance?
No. The circular provides relief from additional filing fees for specified forms, but it does not automatically waive penalties, adjudication exposure or other consequences arising from a separate statutory default.
6. Can a company choose between MGT-7 and MGT-7A based on the filing relaxation?
No. The relaxation does not change form applicability. MGT-7 or MGT-7A must still be selected based on the company’s legal status and the applicable Companies Act and Rules.
7. Does the relaxation apply to every AOC-4 variant?
Only the AOC-4 variants expressly listed in General Circular No. 05/2026 are covered. Companies should verify the applicable form before relying on the relaxation.
8. Can the same MCA relaxation be applied to ADT-1, MGT-14 or DIR-3 KYC?
No. These forms are not covered merely because they are ROC or company compliance forms. Any relief for them must arise from a separate notification, circular or legal provision.
9. Can Ebizfiling review whether a company has a filing default even if additional fees are currently relaxed?
Yes. Ebizfiling can assist in reviewing the original statutory due date, AGM position, applicable annual return form and whether any separate compliance default exists despite the filing-fee relaxation.
10. Can Ebizfiling help determine whether a company should file MGT-7 or MGT-7A?
Yes. Ebizfiling can review the company’s legal status and applicable annual return requirements to identify the correct form based on the facts and documents provided.
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