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The compliance calendar every private limited company misses

AOC-4 and MGT-7 are well known. These six obligations generate most of the penalties we are asked to clean up.

Sheetal Mehta · Head of Legal & Compliance 9 January 2026 7 min read

Penalties accrue per day, without a cap

Most Companies Act penalties run at ₹100 per day per form with no upper limit. A single forgotten form left for a year becomes ₹36,500. Directors carry personal liability for several of them.

The six most commonly missed

In cleanup engagements, the same obligations appear again and again.

  • DIR-3 KYC — every director, every year by 30 September. Non-filing deactivates the DIN.
  • INC-20A — commencement of business declaration within 180 days of incorporation.
  • ADT-1 — auditor appointment within 15 days of the AGM.
  • MSME-1 — half-yearly return of payments outstanding to MSME suppliers beyond 45 days.
  • DPT-3 — annual return of deposits and exempted deposits, including director loans.
  • BEN-2 — significant beneficial ownership declaration, frequently ignored entirely.

Board meetings and minutes

Four board meetings a year with no more than 120 days between any two. Minutes must be recorded within 30 days and entered in a bound minute book. Backdated minutes produced during an inspection are a serious problem, not a fix.

Build the calendar in April

At the start of every financial year, list each applicable form against its due date and assign a named owner with a reminder ten days ahead. That single hour of work prevents almost every penalty we are later asked to regularise.

Key takeaway

Set the year's calendar in April with named owners. Late fees under the Companies Act have no ceiling, and cleanup always costs more than compliance.

#ROC compliance#private limited company#MCA filing#DIR-3 KYC

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