More Time for Compliance! MCA Annual Filing Date Extended

MCA Annual Filing Deadline Extended Without Late Fees

(General Circular No. 08/2025 dated 30 December 2025)

The Ministry of Corporate Affairs (MCA) has provided significant compliance relief by issuing General Circular No. 08/2025 dated 30 December 2025, extending the timeline for filing Annual Returns and Financial Statements for FY 2024-25 without charging any additional (late) fees.

This extension comes as a major relief for companies, directors, and compliance professionals (CA/CS/CMA) who were unable to complete their annual filings within the original statutory deadlines.

1. Context of the MCA Circular

Earlier, MCA had released General Circular No. 06/2025 dated 17 October 2025, granting partial relaxation from additional fees for certain annual filings. Following continued representations from stakeholders and considering genuine practical challenges, MCA has now further extended this relaxation through Circular No. 08/2025, with approval from the Competent Authority.

2. Revised Due Date – Major Relief

✅ New final date: 31 January 2026

Companies may now file their annual compliance forms for FY 2024-25 up to 31 January 2026 without incurring any additional fees.

⚠️ This relief applies only to the waiver of late fees. Normal filing fees, wherever applicable, must still be paid.

3. MCA Forms Covered Under the Extension

The waiver applies to the following e-forms related to Annual Returns and Financial Statements for FY 2024-25:

📄 Annual Return Forms

  • MGT-7

  • MGT-7A (OPC and related entities)

📊 Financial Statement Forms

  • AOC-4

  • AOC-4 XBRL

  • AOC-4 CFS

  • AOC-4 CFS NBFC (Ind AS)

  • AOC-4 NBFC (Ind AS)

4. Meaning of “Without Additional Fees”

  • No late fee or additional fee will be levied if the above forms are filed on or before 31 January 2026.

  • Filings made after this date will attract normal additional fees and penalties as prescribed under the Companies Act, 2013.

  • This is a one-time compliance relaxation and should be utilized prudently.

5. Key Clarifications

📌 Only the filing deadline has been extended; all statutory requirements, disclosures, and certifications remain unchanged.
📌 The circular does not grant immunity from penalties for any other violations under the Companies Act.
📌 The benefit is restricted strictly to FY 2024-25 and does not apply to previous years.

6. Who Stands to Gain the Most?

This extension is particularly helpful for:

  • Companies affected by audit delays

  • Entities facing MCA portal or technical issues

  • Start-ups, SMEs, and NBFCs

  • Professionals managing large volumes of annual filings

  • Companies seeking to avoid substantial late fees and penal exposure

7. Recommended Action Points

✔ Identify pending MGT-7 / MGT-7A / AOC-4 filings for FY 2024-25
✔ Finalise accounts and obtain necessary approvals immediately
✔ Avoid last-minute filing to prevent portal congestion
✔ Ensure correctness of data to avoid future notices
✔ Maintain proof of filing completed before 31 January 2026

Final Takeaway

31 January 2026 is the last and final opportunity to complete MCA Annual Filings for FY 2024-25 without incurring additional fees. Missing this deadline may lead to substantial late fees and penal consequences for both the company and its officers.

This MCA relaxation should be viewed as a valuable compliance window, not a reason to delay further.

Why 31 December Is So Important for Professionals and Businesses

31st December 2025 is far more than just the close of the calendar year.
It marks one of the most crucial compliance cut-off dates under GST, Income Tax, and MCA regulations for FY 2024-25 / AY 2025-26.

For Chartered Accountants, tax consultants, business owners, companies, and professionals, overlooking this deadline can lead to loss of refunds, late fees, penalties, and long-term litigation exposure.

Let us break down why this single date carries such immense importance.

🔴 1. Deadline for Filing GSTR-9 (GST Annual Return) – FY 2024-25

GSTR-9 is the annual GST return that provides a consolidated view of:

  • Outward supplies

  • Inward supplies

  • Input Tax Credit (ITC) claimed

  • Taxes paid

  • Year-end adjustments

Important points to note:

  • 31st December 2025 is the statutory due date for filing GSTR-9 for FY 2024-25

  • Filing is optional for taxpayers with AATO up to ₹2 crore

  • Once submitted, GSTR-9 cannot be revised

This return plays a key role in:

  • GST scrutiny proceedings

  • Departmental notices

  • ITC verification and reconciliation

Who needs to be especially cautious?

  • Businesses with multiple amendments during the year

  • Taxpayers who rectified FY 2024-25 errors in FY 2025-26

  • Taxpayers facing ITC mismatches with GSTR-2B

🔴 2. Due Date for Filing GSTR-9C (GST Reconciliation Statement)

GSTR-9C is a reconciliation statement comparing:

  • Audited financial statements

  • GSTR-9 annual return

Key highlights:

  • Applicable to taxpayers whose turnover exceeds the prescribed audit limit

  • 31st December 2025 is the final due date

  • Although now self-certified, it remains a high-risk compliance document

Any mismatch may trigger:

  • GST audits

  • Demand notices

  • Interest and penalty proceedings

🔴 3. Final Date to File Belated or Revised ITR – AY 2025-26

This is one of the most overlooked yet most critical year-end deadlines.

What closes on 31st December 2025?

  • Filing of Belated Income Tax Returns

  • Filing of Revised Income Tax Returns

Why this date is crucial:

  • It is the last chance for non-filers to submit their return

  • Errors in earlier returns can no longer be corrected after this date

  • Unclaimed income tax refunds may lapse permanently

Who should be extra alert?

  • Salaried individuals awaiting refunds

  • Professionals and freelancers with TDS deductions

  • Businesses that filed incorrect or incomplete returns earlier

  • Taxpayers who have received CPC intimations or mismatch notices

    🔴 4. MCA Annual Compliance – Extended Due Date up to 31st December 2025

    The Ministry of Corporate Affairs (MCA) has permitted companies to complete their annual compliance filings for FY 2024-25 on or before 31st December 2025.

    Forms included:

    • AOC-4 – Filing of financial statements

    • MGT-7 / MGT-7A – Annual return

    Why this deadline matters:

    • Filing within the extended timeline helps avoid substantial additional fees

    • Failure to comply may result in:

      • Monetary penalties on the company

      • Personal penalties on directors

      • Long-term risk of director disqualification

    🔴 5. PAN–Aadhaar Linking – Practical Year-End Implications

    While PAN–Aadhaar linking requirements differ based on taxpayer categories, 31st December 2025 effectively serves as a practical deadline to ensure:

    • Hassle-free income tax return filing

    • Timely processing of tax refunds

    • Prevention of PAN becoming inoperative for income tax purposes

    Taxpayers with pending PAN–Aadhaar linkage issues frequently encounter:

    • Delays or blockage of refunds

    • Difficulties in filing returns

    • Increased scrutiny, notices, and compliance-related delays

      📌 Professional Compliance Checklist – Tasks to Complete Before 31st December 2025

      ✔ Ensure filing of GSTR-9 for FY 2024-25
      ✔ Submit GSTR-9C wherever reconciliation requirements apply
      ✔ File belated or revised Income Tax Returns for AY 2025-26
      ✔ Complete MCA annual compliances, including AOC-4 and MGT-7 / MGT-7A
      ✔ Confirm and regularise PAN–Aadhaar linkage status
      ✔ Finalise reconciliations, verifications, and supporting documentation