Pvt Ltd Annual Compliance Checklist: AOC-4, MGT-7A, and the Small-Company Trap

These two filings are the backbone of your company's annual compliance — every Pvt Ltd company owes them, every year, regardless of whether you did any business. Miss them and the cost isn't one number, it's two separate mechanisms stacking on top of each other, which is exactly the part most online guides get wrong.

AOC-4 (financial statements): what it is and when it's due

AOC-4 is the annual filing of your company's financial statements with the ROC. It's due within 30 days of your Annual General Meeting (AGM), and your AGM itself must be held by 30 September following your financial year end (for a standard 31 March FY). For FY 2025-26, with an AGM held by 30 September 2026, AOC-4 would be due by roughly 29 October 2026 — that specific 2026 date is illustrative, derived from an assumed 30 September AGM, not a fixed statutory date, so confirm it against your own AGM date rather than treating it as universal.

One Person Companies (OPCs) are the exception — they don't hold an AGM, and file AOC-4 within 180 days of their financial year end instead.

MGT-7 vs MGT-7A: the small-company trap

MGT-7 is the standard annual-return form for companies generally. MGT-7A is a simplified version introduced for One Person Companies and Small Companies, available since FY 2020-21. Here's the trap: most early-stage Pvt Ltd companies meet the statutory 'small company' definition and should be filing MGT-7A, not MGT-7 — but a lot of guidance (and a lot of founders) default to MGT-7 out of habit or unfamiliarity with the small-company carve-out. Before you file, check your applicability against the small-company definition first, rather than assuming MGT-7 is your form by default.

Either way, the same 60-day-from-AGM deadline applies — roughly 29 November for an AGM held by 30 September.

The penalty, unpacked: two separate mechanisms, not one number