Annual ROC filing for a private company is a sequence, not a single event — each step has a deadline that depends on the one before it, starting with the AGM date rather than the financial year-end.
1. Board meeting to approve financial statements
The board must approve the financial statements before they can be adopted at the AGM. This typically happens once the statutory audit is complete, so the audit timeline effectively sets how early the rest of the sequence can start.
2. Annual General Meeting (AGM)
For a private company, the AGM must be held within six months of the end of the financial year (so, by 30 September for a 31 March year-end), except for a company's first AGM, which gets nine months from financial year-end. Financial statements are adopted by shareholders at the AGM.
3. AOC-4 — financial statements
Due within 30 days of the AGM. Filed with the audited financial statements, auditor's report, board's report, and CSR report where applicable. Companies with certain thresholds file AOC-4 (XBRL) instead of the standard form.
4. MGT-7 / MGT-7A — annual return
Due within 60 days of the AGM. MGT-7A is the abridged version available to small companies and OPCs; other companies file the full MGT-7. This is where shareholding pattern, director details and indebtedness are reported as they stood on the financial year-end date — not the AGM date.
5. DIR-3 KYC — director KYC
An annual requirement for every director with a DIN, independent of the company's own filing cycle, due by 30 September each year. Missing it deactivates the DIN until the KYC is filed with a late fee.
Event-based filings that don't wait for the annual cycle
Separately from the annual sequence above, several filings are triggered by events rather than dates and are generally due within 30 days of the event: DIR-12 for a change in directors, PAS-3 for allotment of shares, CHG-1 for creation of a charge on company assets. These run on their own clock regardless of where the company is in its annual filing cycle.
Late filing
Missing AOC-4 or MGT-7 attracts an additional filing fee per day of delay under the Companies (Registration Offices and Fees) Rules — it accumulates daily with no cap, which is what makes catching a missed filing early worth doing.
This is general information about the Companies Act, 2013 annual filing requirements for a private company, current as of the publish date above. Specific thresholds (e.g. for XBRL or small-company status) depend on the company's own financial figures.