The annual filing calendar, and what a missing year actually means
AOC-4 and MGT-7 have precise deadlines. Knowing them tells you whether a company's missing year is late, alarming, or not yet due at all.
You are looking at a company’s file, and the most recent accounts are for the year ended March 2024. It is now September 2026.
Is that alarming? It depends entirely on a calendar most people reading filings have never had cause to learn, and getting it wrong goes both ways. People panic at a gap that is not yet due, and shrug at one that has been open long enough to disqualify every director in the company.
So here is the calendar, and then the far more useful part: how to read a missing year against it.
Nearly everything written about these deadlines is written for the company that has to meet them. This is written for the person reading the file afterwards.
The calendar, precisely
Two filings a year, and both of them hang off a meeting.
The financial year ends on 31 March for essentially every Indian company.
The annual general meeting must be held within six months of that, so by 30 September, and not more than fifteen months may elapse between one AGM and the next. That is section 96 of the Companies Act 2013. A newly incorporated company gets longer for its first one: within nine months of the close of its first financial year. The registrar may also extend the time for any AGM other than the first, by up to three months, but only “for any special reason”, so treat an extension as a possible explanation for a late filing rather than something every company can help itself to.
One exception to hold on to: a one person company does not hold an AGM at all. Section 96 excludes it, so the whole calendar below reads differently for an OPC, which files its accounts within 180 days of the close of the financial year instead.
Form AOC-4, the financial statements, is due within 30 days of the AGM. Section 137.
Form MGT-7, the annual return, is due within 60 days of the AGM. Section 92(4). A one person company or a small company files the abridged MGT-7A instead.
Both provisions have a limb for the company that simply never held the meeting. Section 92(4) runs the sixty days from the date the AGM should have been held, with a statement of reasons attached, and section 137(2) does the same for the accounts. Skipping the AGM does not stop the clock.
Put the normal case together and the “on time” window looks like this:
| Event | Latest ordinary date |
|---|---|
| Financial year ends | 31 March |
| AGM held | 30 September |
| AOC-4 filed | roughly 30 October |
| MGT-7 or MGT-7A filed | roughly 29 November |
For LLPs the calendar is different and the dates are fixed rather than meeting-dependent. Form 11, the annual return, is due by 30 May. Form 8, the Statement of Account and Solvency, by 30 October. We have written separately on what the register shows about an LLP, which is less than it shows about a company.
So when is a gap actually a gap?
This is the table to keep. Read the month you are checking in against the financial year you are wondering about.
| You are checking in | The last filed year should be | If it is not |
|---|---|---|
| April to September | The year ended 31 March last year | Overdue by a year or more |
| October to November | Same, and the current year is landing now | Watch, do not conclude |
| December to March | The year ended 31 March this calendar year | Overdue |
Applied to the example at the top: it is September 2026, so the year ended 31 March 2025 should have been filed by around November 2025. Accounts that stop at March 2024 mean one full year is missing and overdue, and the year ended March 2026 is not yet due. That is a real gap, and it is a single one.
The thing to avoid is the common misreading in the other direction. In July 2026, a company whose latest accounts are for the year ended March 2025 is entirely up to date. The March 2026 accounts are not late. They are not due for another four months.
What it is costing them
A filing gap is not passive. It has a running meter.
The additional fee. Under the Companies (Registration Offices and Fees) Second Amendment Rules 2018, notified on 7 May 2018, a late annual filing attracts an additional fee of ₹100 per day, charged separately for the section 92 form and the section 137 form, wherever the filing period expired after 30 June 2018. There is no upper limit on it, and section 403 backs that up by requiring the prescribed additional fee to be “not less than one hundred rupees per day”. Both forms late means ₹200 a day. Two years late is a six-figure number before anyone has been penalised for anything.
The penalties, which are separate from the fee. Under section 92(5), for failing to file the annual return, the company and every officer in default face ₹10,000 and a further ₹100 for each day the failure continues, capped at ₹2,00,000 for the company and ₹50,000 for an officer. Under section 137(3), for the financial statements, the company faces ₹10,000 and a further ₹100 per day up to ₹2,00,000. The same ₹10,000 and ₹100 a day, capped at ₹50,000, falls on the managing director and the chief financial officer; failing them, on the director the board charged with complying; failing that, on all the directors.
If you have seen ₹1,000 a day quoted for the company under section 137(3), that was the position before 21 December 2020, when the Companies (Amendment) Act 2020 replaced it.
This is why a sustained gap is so informative. Nobody forgets for two years. A company that has not filed has either decided not to, or cannot: no audited accounts, no auditor willing to sign, no money for the fee, or nobody left who cares.
What it escalates to
Two consequences matter to you as an outsider, because both are visible.
Every director gets disqualified. Section 164(2) says that a person who is or has been a director of a company which has not filed financial statements or annual returns for any continuous period of three financial years is not eligible to be reappointed as a director of that company, or appointed in any other company, for five years. That is not a fine. It follows the individual into every other board they sit on, and registrars publish lists of directors disqualified this way.
So three consecutive missing years is a threshold, not a slope.
And the company gets removed, though not quite for the reason people assume. Non-filing is not itself a ground under section 248(1). The ground that does the work is clause (c): that the company “is not carrying on any business or operation for a period of two immediately preceding financial years and has not made any application within such period for obtaining the status of a dormant company”. Prolonged silence on the filing side is the evidence a registrar reads as showing exactly that. This is how most Indian companies actually end. In our snapshot of the register taken on 8 September 2026, more than one in four entities carried a strike-off status, against fewer than two thousand under a corporate insolvency resolution process. The full breakdown is in how many companies in India actually still exist.
The sequence, then, runs: filings stop, fees accrue, directors are disqualified at year three, and at some point the registrar removes the company. If you are watching a counterparty, you are watching a process with stages, not a single event.
How to read a gap, in one table
| What you see | How to read it |
|---|---|
| Filed every year, near the deadline | Normal. Most companies file in the last fortnight |
| One year missing, not yet due | Nothing. Check the date before you worry |
| One year missing and overdue | Note it. Could be an auditor delay, a dispute, or cash |
| Two consecutive years missing | Serious. Something is wrong, or nobody is minding it |
| Three or more | The directors are heading for disqualification, and the registrar for strike off |
| Filings stop and directors resign in the same window | The worst combination on this page |
That last row deserves the emphasis. Director changes are filed separately from the annual filings, so you can see them even when the accounts have stopped coming. A cluster of resignations around the point the filings ceased tells you the people closest to the company reached a conclusion before you did.
If the company owes you money, this reading is the core of the exercise, and we have set it out end to end in what the filings tell you about whether a customer can pay.
What a gap does not mean
It does not mean the company is a fraud. The single commonest reason for a late filing in a small company is that the accounts were not ready and the auditor signed late. It is untidy, not sinister.
It does not mean the company has stopped trading. Plenty of working businesses are behind on compliance. Filing discipline and commercial health overlap; they are not the same thing.
And filing on time does not mean the numbers are good. A company can file promptly, every year, and be losing money throughout. Punctuality is a signal about the company’s administration, not about its balance sheet. For that you have to read the accounts themselves.
One more, and it is the one people get wrong most often. “I could not find the filing” is not the same as “the filing does not exist”. The portal serves one document category at a time and it is easy to look in the wrong one. Before you conclude that a year is missing, make sure you looked in Annual Returns and Balance Sheet eForms for all years, not for the year you happened to select.
What to do with it
- Work out today’s date against the calendar above before you call anything late.
- Count consecutive missing years, not total ones. Three in a row is the threshold that changes the legal position.
- Check director changes over the same window. They are in a different category and they are the corroborating signal.
- Check the status field. If the registrar has already started, it will say Under process of striking off, and what each status means sets out what follows from each one.
- Note the date you checked, and keep the evidence. A gap you can demonstrate later is worth more than one you remember.
The calendar is dull and it is the difference between reading a file correctly and reading it in a panic. Two dates in the autumn, one meeting, two forms. Everything else follows from whether they happened.
Written by the Entiva team, who read Indian company filings for a living. Not legal advice.
Frequently asked
When are AOC-4 and MGT-7 due?
Both hang off the annual general meeting. For a company with a 31 March year end, the AGM must be held by 30 September. Form AOC-4, the financial statements, follows within 30 days of that meeting. Form MGT-7, the annual return, follows within 60 days. So for a normal year the accounts are due by about 30 October and the annual return by about 29 November.
What happens if a company does not file its annual return?
An additional fee of ₹100 per day per form accrues with no cap, and penalties apply under sections 92(5) and 137(3) of the Companies Act 2013. If the failure runs for three continuous financial years, every director of that company is disqualified under section 164(2). And prolonged non-filing is the usual evidence that a company is not carrying on business, which is the actual ground for strike off under section 248(1)(c).
Is a company with one missing year in trouble?
Not necessarily, and often it is not even late. Check the date before you conclude anything: a filing for the year ended 31 March is not overdue until roughly the end of that calendar year. Two or more consecutive missing years is a different matter.
