For a Private Limited Company, annual ROC filings are non-negotiable. Missing them attracts a penalty of Rs. 100 per form per day with no upper limit, plus potential prosecution. This checklist covers what to file and when.
AOC-4: Financial Statements
AOC-4 files the company's audited financial statements with the Registrar of Companies. It is due within 30 days of the Annual General Meeting. The form includes the balance sheet, profit and loss account, and director's report.
MGT-7 / MGT-7A: Annual Return
MGT-7 (or MGT-7A for small companies) files the annual return, due within 60 days of the AGM. It captures shareholding, directors, indebtedness and other corporate details. MGT-7 must be certified by a practising company secretary for certain companies.
ADT-1: Auditor Appointment
ADT-1 files the appointment or reappointment of the statutory auditor, due within 15 days of the AGM in which the appointment was made. Missing this is a common but easily avoidable default.
Event-based filings
Beyond annual filings, event-based forms are required for director changes (DIR-12), share allotments (PAS-3), address changes (INC-22), and charge creation or modification (CHG-1). Each has its own deadline.
Penalties for delay
Late filing attracts Rs. 100 per day per form with no cap. For a company with three overdue forms, that is Rs. 300 per day until filed. Over months, the penalty can exceed the cost of compliance many times over.
ROC compliance is a calendar problem, not a knowledge problem. Build the filing calendar at the start of the year, file on time, and never let an event-based filing slip. The penalty mathematics make delay indefensible.
