Don't Miss ROC Annual Filing: New Rules for Form AOC-4 & MGT-7
Major Changes in ROC Annual Filing

According to the latest sources, the Ministry of Corporate Affairs (MCA) is scheduled to roll out the final set of 38 company forms, effective from July 14, 2025. This significant update marks a crucial transition for companies as they adapt to the new compliance requirements.

Here are some key highlights of the significant updates made to various MCA forms, including AOC-4, MGT-7/7A, ADT-1, and others:

Key Updates to MCA Form AOC-4

  • The upcoming web form will include extracts from both the auditor’s report and the board’s report, offering users key financial insights and important updates.
  • Forms AOC-1 and AOC-2 will be introduced as new web-based components within the AOC-4 form.
  • AOC-4 now supports both online and offline filing modes, offering users greater flexibility based on their connectivity preferences.
  • The Board's Report and Auditor's Report must be submitted together as a consolidated filing under AOC-4.
  • The Corporate Social Responsibility (CSR) section has been excluded from the AOC-4 form documentation.
  • Going forward, there will no longer be separate forms for the Consolidated Financial Statement (CFS). The AOC-4 CFS has been integrated into the AOC-4 form, streamlining the submission process.
  • AOC-4 is available for companies undergoing the Corporate Insolvency Resolution Process (CIRP) or liquidation.
  • The data from the previous year will be pre-filled in AOC-4, but it will be editable with a required explanation for any changes made.
  • Offline Functionality: Users can download the Excel utility, enter the required data offline, and then upload it to the portal.
  • The AOC-4 CFS in version 3 can be filed separately from the AOC-4 submitted in version 2.
  • When filing AOC-4 CFS separately, it's important to ensure that both the Audit Report (AR) and Director’s Report (DR) are correctly linked, as this is vital for maintaining accuracy and transparency in financial reporting.
  • AOC-1 will only be accessible when the associate or subsidiary is enabled.
  • The AOC-2 form will only be accessible when Related Party Transaction (RPT) transactions are enabled.
  • CSR-2 does not have any independent offline modes; it only operates in online mode.
  • The AOC-4 form for Non-Banking Financial Companies (NBFCs) is essentially the same as the standard AOC-4 form. This applies similarly to the CFS (Companies Financial Statements).
  • The AOC-4 XBRL will now mandate the inclusion of signed financial statements in XML format.
  • Current XBRL taxonomies will remain in effect.

Key Updates in Forms MGT-7 and MGT-7A

  • There are no linked filings for forms MGT-7 and MGT-7A.
  • The list of shareholders and debenture holders is now available in Excel format.
  • The Board meetings are now accessible in Excel format, which includes details on shareholder meetings and committee meetings.
  • A separate person table for BO supplies has been introduced.
  • Items such as the company's name and address are added at the year-end.
  • Photos of the company's interior and exterior should be submitted with MGT-7 and MGT-7A.
  • The MGT-8 attachment has been removed and merged into the main form.
  • MGT-7 and MGT-7A are now available for companies undergoing Corporate Insolvency Resolution Process (CIRP) or liquidation.
  • The maximum attachment size for the shareholders list is 300 MB, which consists of 15 files with a limit of 20 MB each. This applies only to MGT-7 and not to MGT-7A.
  • The shareholders list that is currently not available will be included in the generated PDF for MGT-7 and MGT-7A, similar to how it appears in PAS-3.

The Total File Size Has Been Increased

The AOC-4 forms, which include AOC-4 CFS, AOC-4 XBRL, AOC-4 NBFC, and AOC-4 NBFC CFS, now have increased size restrictions. Each individual file can now surpass the previous 2 MB limit, and the overall allowed upload size has been increased from 8 MB to 10 MB.

Audit-Related Filing Forms

  • The ADT-1 form is available only in online mode and cannot be accessed in offline mode.
  • The ADT-1 form now includes separate entries for the auditor's membership number and the firm's registration number.
  • The ADT-1 filing form now includes newly introduced fields for audit committee recommendations.
  • A new field has been added to the ADT-1 filing form to specify the nature of the appointment intimation.
  • The ADT-2 form now includes separate fields for the firm's registration number and the auditor's membership number for those signing the balance sheet.
  • The ADT-4 filing form has been added and is available online only; offline mode is not supported.

Read Also: ROC Forms: Essential Details & Benefits for the PVT Company

Additional Forms

  • The CRA-2 form is available only in online mode and is not accessible in offline mode.
  • The nature of the appointment notification has been added to form CRA-2.
  • Kindly include separate sections for mergers and demergers in Form CRA-2
  • The CRA-4 is the filing form for XBRL. New fields have now been added for the GNL-1 SRN.
  • The CRL-1 filing form is only available online and cannot be accessed offline.
  • The FO service details for the CRL-1 subsidiary have been removed and will now be directly integrated into the form.
  • The MGT-15 filing form has a new field indicating the financial year related to the AGM.
  • The MGT-15 filing form must also be signed by the Chief Security Officer, designated as a Key Managerial Personnel (KMP).
  • The filing form MGT-15 is now enabled for companies undergoing CIRP (Corporate Insolvency Resolution Process) or liquidation, in addition to being available for annual filings.
  • GNL-1 is currently in its non-STP form
  • A new field for DIN or PAN has been added under the 'Other Applicant Details' section of GNL-1.
  • The 'Period of Default' field has been added to GNL-1 for the purpose of compounding offences.
  • The Annual General Meeting(AGM) due date in GNL-1 has been set, and an extension request has been included for compounding purposes.
  • The appearance of CSR-1 has changed, and it feels different now. Won’t feel sad anymore.
  • The CSR-1 area now includes added fields for locality information.
  • CSR-1, Part 1, Section 8 outlines converting a regular company into a Section 8 company, which operates as a nonprofit organization.
  • The INC-22A does not involve significant changes.
  • The complaint forms (ICP and SCP) are non-STP forms, which have been merged into a single document.
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