AGM Season Is Here: AOC-4, MGT-7, ADT-1 Deadlines and a Closing Amnesty Window

If your company's financial year ended 31st March 2026, the Annual General Meeting has to be held by 30th September 2026 — and every year, without fail, we see a cluster of directors treat the AGM itself as the finish line rather than the starting gun. It isn't. The AGM is what starts the clock on AOC-4 and MGT-7, and it is entirely possible to hold a perfectly compliant AGM on time and still walk into a late-filing penalty a month later because the filing sequence afterward wasn't planned.

The Filing Sequence, and Why Order Matters

Three filings follow from an AGM, each with its own trigger date:

The counters run from the actual date of the AGM, not from the financial year-end and not from the statutory last date by which the AGM should have been held. A company that holds its AGM early — say, on 5th September rather than waiting until the 30th — pulls all three downstream deadlines forward with it. Conversely, a company that (with proper approval) extends its AGM date pushes every subsequent deadline out correspondingly. Track the deadlines from the meeting you actually held, not a generic date pulled from a compliance calendar template.

The sequencing point that trips up the most companies: MGT-7 cannot be filed until AOC-4 has been successfully processed by the MCA, because the annual return draws its financial data from the filed financial statements. If AOC-4 is filed at the last hour on day 30 and gets stuck in processing or requires resubmission, the 60-day MGT-7 window starts eroding with no buffer left. File AOC-4 with real margin, not against the deadline.

What a Miss Actually Costs

AOC-4 and MGT-7 sit in the harshest fee regime the MCA runs. Since 1st July 2018, both forms accrue a flat ₹100 per day per form, with no upper cap. There is no 15-day grace period and no multiplier ladder that tops out — the meter simply keeps running:

• Six months late on both forms together works out to roughly ₹36,000 in additional fees alone.
• A full year's delay crosses ₹73,000 — before any adjudication proceeding is even opened.

ADT-1 sits in a different, gentler regime — it is one of only two forms (the other being DIR-3C) that get a 1x grace band for the first 15 days of delay, after which the multiplier steps up through 2x, 4x, 6x, 10x, and 12x across widening delay brackets. This 1x-for-15-days treatment is specific to forms filed under Sections 139 and 157 of the Companies Act; it does not extend to AOC-4 or MGT-7, despite being commonly and incorrectly assumed to apply across the board.

The normal fee that these multipliers apply to is itself tied to the company's authorised share capital:

The additional fee is charged on top of the normal fee, not instead of it — a ₹300 form filed even one day late costs ₹300 plus the multiplier-applied additional fee, not ₹300 alone.

A Closing Window: CCFS-2026

For any company carrying a backlog of unfiled AOC-4, MGT-7/7A, or ADT-1 from earlier years, there is a materially better option available right now than filing at the full ₹100-a-day rate. The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) allows pending annual filings to be regularised at the normal fee plus just 10% of the accrued additional fees, with immunity from prosecution for the filing default — a 90% discount on what would otherwise be owed, alongside relief from the criminal-liability exposure that attaches to prolonged non-filing under the Companies Act.

This scheme has already been extended twice by the Ministry of Corporate Affairs — first from its original closing date, and again to its current, 15th September 2026 deadline. Two extensions is not a pattern to assume will repeat a third time. For any company with a compliance backlog — and in our experience, small private companies that went dormant, changed management, or simply lost track of a filing during a transition year are the most common candidates — this window closing tomorrow is the difference between clearing the backlog at a fraction of the statutory fee, or facing the uncapped ₹100-a-day meter plus a separate adjudication process once the amnesty lapses.

Practitioner Note: If your company has any pending AOC-4, MGT-7, or ADT-1 from a prior financial year sitting unfiled, the arithmetic almost always favours filing under CCFS-2026 before the window shuts, even at short notice — the accrued additional fee on a multi-year backlog is precisely the number the scheme cuts by 90%. Confirm eligibility today; this is not a deadline that rewards waiting for the next extension announcement.

Filing Checklist for This AGM Season

1. Confirm your actual AGM date and calculate ADT-1, AOC-4, and MGT-7 deadlines from that specific date, not from 30th September as a default.
2. File AOC-4 well inside the 30-day window, leaving enough buffer for MCA processing before starting MGT-7, which depends on it.
3. Check for any pending prior-year AOC-4, MGT-7, or ADT-1 and evaluate CCFS-2026 eligibility before the 15th September 2026 closing date.
4. Verify the authorised-capital fee slab your company falls into, so the normal fee (and any applicable multiplier) is calculated correctly rather than assumed.
5. File ADT-1 within 15 days of the AGM if a new auditor was appointed or the existing appointment was ratified — this form is easy to overlook once AOC-4 and MGT-7 take priority attention.

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