The AOC-4 and MGT-7 due date extension for FY 2025-26 is real, and it is narrower than it looks. Under General Circular No. 05/2026, dated 24 October 2026, the Ministry of Corporate Affairs has given companies until 31 December 2026 to file AOC-4 and its variants, and until 31 January 2027 to file the MGT-7 and MGT-7A annual return, in both cases without the additional fee that would normally accrue for late filing. That is welcome breathing room — but reading it as “the deadlines moved, relax” is how a company walks into a default it still owns. The relief is real; so are its limits.
These additional-fee relaxations are not new — MCA has issued similar circulars in recent years when the filing season runs into portal congestion and version changes — but each one is specific about what it covers. This year’s is specific in three ways that decide whether it actually helps you: it covers only two forms, it leaves the AGM untouched, and it unwinds completely if you miss the extended date.
What the AOC-4 and MGT-7 due date extension for FY 2025-26 actually says
The circular relaxes the additional-fee clock on two annual filings for the financial year ended 31 March 2026. AOC-4 — the form through which your audited financial statements go on the public record — and its variants AOC-4 CFS, AOC-4 XBRL and the AOC-4 NBFC (Ind AS) forms can be filed up to 31 December 2026. MGT-7 and the MGT-7A annual return can be filed up to 31 January 2027. Within those windows, only the normal filing fee applies; the additional fee for delay is waived.
Set against the ordinary statutory clock, that is roughly a two-month cushion. For a company whose AGM fell on the last permissible date of 30 September 2026, AOC-4 was otherwise due within 30 days of the meeting — 30 October 2026 — and the MGT-7 annual return within 60 days — 29 November 2026. The circular pushes the fee-free filing date for those forms out to 31 December and 31 January respectively.
| Filing (FY 2025-26) | Original due date | Fee-free filing date under Circular 05/2026 |
|---|---|---|
| AOC-4 / AOC-4 CFS / XBRL / NBFC | 30 October 2026 | 31 December 2026 |
| MGT-7 / MGT-7A | 29 November 2026 | 31 January 2027 |
| Holding the AGM | 30 September 2026 | Not extended |
The extension is on filing, not on your AGM
This is the line most easily missed. The circular relaxes the filing of AOC-4 and MGT-7; it does not extend the statutory time for holding the annual general meeting. A company that was required to hold its AGM by 30 September 2026 and did not is still in default under the Companies Act, 2013, and the relaxation does nothing to cure that. The two extra months are for lodging forms for a meeting that should already have happened — not for deciding when to hold it. If you were counting on the circular to buy time on the meeting itself, it does not.
The extra time is to file the forms, not to hold the meeting. If your AGM has not been held, that is a separate default the circular does not touch.
Relief on the clock is not relief on the work
The forms are the last step, not the task. AOC-4 carries the audited financial statements, the board’s report and the auditor’s report; MGT-7 carries the annual return with the shareholding, the directors and the other particulars as on the year-end. None of that is affected by the circular. The accounts still have to be finalised, audited and adopted at a validly held AGM before either form can be filed. If the audit is not complete, or the AGM was not held, a later filing date buys nothing — the form still cannot be lodged correctly. The companies that benefit from the extension are the ones already close to done and held up by the portal or a last correction, not the ones who read it as permission to start in December.
Miss the extended window and the relief disappears
The waiver is time-boxed, and the way it unwinds is the part worth pinning down. File AOC-4 after 31 December 2026, or MGT-7 after 31 January 2027, and the additional fee is calculated from the original due date — 30 October 2026 for AOC-4 and 29 November 2026 for MGT-7 — not from the extended date. Slipping one day past the extended window does not cost you one day of additional fee; it costs you the whole run from the original deadline, as if the relaxation had never applied. The additional fee for annual forms climbs with the length of the delay, so the gap between “filed by 31 December” and “filed in January” is not marginal.
The sensible reading, then, is the unglamorous one: treat 31 December and 31 January as hard dates, not as a reprieve; close the accounts and complete the audit on the original timetable; and use the two months only as a buffer against the ROC portal queue and last-mile corrections. If you are not sure the AOC-4 package is complete and correctly tagged, or whether your AGM was validly held and minuted, that is the thing to resolve now — the filing date was always the easy part.