AOC-4 and MGT-7: due dates from your AGM, and the ₹100/day penalty

Every autumn, the same conversation repeats in CA and CS offices across India. The AGM is done — or nearly done — and someone asks: "So when exactly are AOC-4 and MGT-7 due this year?" The answer is never a fixed calendar date, because neither form is anchored to the calendar. Both are anchored to your AGM — and the penalty for missing them, at ₹100 per day with no cap, is the least forgiving in Indian compliance.

The two forms, and what they carry

• AOC-4 files the company's financial statements — balance sheet, profit and loss, and the accompanying reports — with the Registrar of Companies (Section 137 of the Companies Act, 2013).
• MGT-7 files the company's annual return — shareholding, directors, meetings and the state of the registers (Section 92). OPCs and small companies file the abridged MGT-7A instead, on the same timeline.

Together they are the public record of the company's year. Banks, investors and counterparties read them; so does the Registrar.

The due dates: 30 days and 60 days from the AGM

AOC-4: within 30 days of the date of the AGM.

MGT-7 / MGT-7A: within 60 days of the date of the AGM.

The count starts from the day the AGM is actually held — not the financial year end, and not the date the statements were signed. Work it for the most common pattern, a company that holds its AGM on the last permissible day, 30 September:

• AOC-4 falls due on 30 October.
• MGT-7 falls due on 29 November.

Hold the AGM earlier and both dates move earlier with it: an AGM on 20 September makes AOC-4 due on 20 October and MGT-7 on 19 November. This is why the two forms escape every printed compliance calendar — the trigger is an event in your company's year, and the deadlines are derived from it. (If, exceptionally, no AGM is held, the count runs from the date the AGM should have been held — the obligation does not dissolve with the meeting.)

The penalty: ₹100 a day, per form, no cap

File either form late and the additional fee runs at ₹100 per day of delay — charged per form, and with no maximum. Set that beside the GST late fee for GSTR-3B, which stops growing at ₹10,000, and the difference in character is obvious: an MCA delay is a meter that never stops.

What the meter actually reads:

• Both forms 15 days late: AOC-4 ₹1,500 + MGT-7 ₹1,500 = ₹3,000.
• Both forms 45 days late: ₹4,500 + ₹4,500 = ₹9,000.
• AOC-4 90 days late, MGT-7 caught up at 60: ₹9,000 + ₹6,000 = ₹15,000.
• A company that discovers last year's forms unfilled, 300 days on: ₹30,000 per form — and the current year's clock is also running.

The fee is only the visible cost. Chronic late filing shows on the company's public record, surfaces in every due-diligence and lender review, and keeps directors' records untidy in ways that take far longer to explain than the fee took to accrue.

Why these two forms slip

The failure pattern is rarely negligence about the forms themselves. It is a chain problem:

1. The audit finishes late, so the statements are not ready for adoption.
2. The AGM slips, or is held on time but its date is recorded in a register nobody consults again.
3. The derived deadlines are never recomputed — the team works from last year's dates, which were derived from last year's AGM.
4. AOC-4 is filed in the October rush and MGT-7 is remembered in December, already two weeks into its meter.

Every link in that chain is a date-management problem, not a knowledge problem. Every firm knows the 30 and the 60. What fails is the arithmetic of from when, for this client, this year — repeated across every company on the roster.

Do the arithmetic for one company in the MCA additional-fee calculator: AGM date in, both due dates and the running fee out. Across a whole roster, that derivation is what every Metiq plan does automatically — each client's AOC-4 and MGT-7 dates recomputed from its own AGM, every year.

FAQ

The AGM is adjourned and concluded on a later date. Which date counts?

The deadlines run from the AGM at which the statements are adopted and the annual return position is settled — in practice, the concluded meeting's date. Keep the meeting record precise; the two filing clocks are set by it.

Is there any cap or slab on the ₹100-per-day fee?

No. The additional fee is ₹100 per day per form and continues until the form is filed. There is no equivalent of the GST ₹10,000 ceiling.

Our company is small / an OPC. Does MGT-7 still apply?

Small companies and OPCs file the abridged annual return, MGT-7A, instead of MGT-7 — same 60-days-from-AGM due date, same ₹100-per-day additional fee. AOC-4 applies as usual.

The financial statements were signed in August. Can AOC-4 be filed then?

No — AOC-4 files the statements as adopted at the AGM. Signing by the board starts the chain; adoption at the AGM is what the 30-day clock runs from.

What if the AGM itself is delayed?

The filing clocks run from when the AGM is held (or should have been held), so a delayed AGM compresses — and can pre-consume — the filing window. It never extends it indefinitely, and it does not pause the additional fee once the due date passes.

Metiq derives AOC-4 and MGT-7 deadlines from each client's recorded AGM date and recomputes them when the meeting moves — so the ₹100-a-day meter is a date on your calendar, not a discovery in December.

General information only — not professional advice.