AOC-4 Filing 2026-27: Complete Guide to MCA V3, Due Dates & Compliance

Complete Guide to AOC-4 Filing for Tax Year 2026-27

By CS Rantu Das, FCS, LL.M. — Founder & Managing Partner, M/s. Rantu Das & Associates, Kolkata

A Kolkata CS founder’s step-by-step field guide to AOC-4 filing under Section 137 of the Companies Act — variants, applicability, MCA V3 workflow, and the errors that cost boards additional fees.

AOC-4 is the annual filing that formally puts a company’s audited financial statements on the public record. Under Section 137 of the Companies Act, 2013, every company — private, public, one-person, or Section 8 — must file a copy of its adopted financial statements with the Registrar within thirty days of the Annual General Meeting. In practice, this is the single most consequential ROC filing in a company’s annual cycle. Late or defective filing triggers additional fees, potential penalties under Section 137(3), and — in the worst cases — director disqualification under Section 164(2).

Here is how I now walk every mid-market company client through the AOC-4 cycle for Tax Year 2026-27.

The four AOC-4 variants — pick the right one first

• AOC-4 (standard) — for companies not required to file in XBRL and not covered by NBFC provisions.
• AOC-4 XBRL — for listed companies, companies with paid-up capital of ₹5 crore or above, companies with turnover of ₹100 crore or above, and companies covered under Companies (Indian Accounting Standards) Rules.
• AOC-4 CFS — for companies that have subsidiaries, associates, or joint ventures and are required to file consolidated financial statements.
• AOC-4 NBFC (Ind AS) — for NBFCs preparing financial statements under Ind AS.

Choosing the wrong variant is the most common first-mistake. If your company crosses any XBRL threshold, standard AOC-4 will not be accepted — the MCA V3 portal now filters variants at upload.

Applicability and due dates

For most companies with a March financial year, AOC-4 must be filed within thirty days of the AGM. If the AGM is held on 30 September 2026 (last permissible date for FY 2025-26), the AOC-4 due date is 30 October 2026. For OPCs, the due date is 27 September 2026 — within 180 days from the end of the financial year, regardless of whether an AGM is held.

Section 8 companies follow the standard AOC-4 timeline. Small companies file AOC-4 (not a simplified version — MGT-7A is the small-company shortcut, but only for MGT-7).

Documents required before you begin

• Audited Balance Sheet and Statement of Profit and Loss
• Cash Flow Statement (if applicable)
• Notes to accounts and significant accounting policies
• Directors’ Report (with all annexures including AOC-1 for subsidiaries)
• Auditor’s Report (with CARO 2020 reporting where applicable)
• Statement of subsidiaries in AOC-1 (if consolidated financials are being filed)
• Secretarial Audit Report (for companies covered under Section 204)
• CSR-2 report for the reporting period (if applicable)

MCA V3 filing workflow

1. Log in to the MCA V3 portal with the authorised director’s DIN and DSC.
2. Select AOC-4 (correct variant) from the annual filing menu.
3. Enter CIN — the form auto-populates company particulars.
4. Upload financial statements (PDF for standard, XBRL instance document for XBRL variant).
5. Attach the Directors’ Report, Auditor’s Report, AOC-1, and any other annexures as separate PDFs.
6. Fill in the AOC-4 form fields — reporting period, board meeting date, AGM date, quantitative details.
7. Verify with two authorised signatories (director + CS if applicable).
8. Affix DSC and submit. Pay statutory fee.
9. Save the acknowledgement (SRN) — this is your filing proof.

Fee structure and late-filing penalty

Statutory filing fee ranges from ₹200 to ₹600 depending on nominal share capital. Beyond the due date, additional fees kick in at ₹100 per day with no cap. On top of the additional fee, Section 137(3) imposes a penalty on the company (₹1,000 per day of default, subject to a maximum of ₹10 lakh) and on every officer in default (₹10,000 plus ₹100 per continuing day, subject to a maximum of ₹50,000). This is why AOC-4 filings should never be treated as a last-day exercise.

Coordination with the statutory auditor

Audit sign-off precedes AOC-4 filing, but the coordination point is subtler than most boards realise. The auditor’s UDIN must appear on the auditor’s report; the CARO 2020 clauses must reconcile with the financial statements; and any subsequent events after the balance sheet date but before AGM must be disclosed. A CS filing AOC-4 without walking through these three points with the auditor invites a defect notice from ROC.

Common errors we still see in 2026

• Wrong AOC-4 variant selected — filing gets rejected at portal validation.
• AOC-1 for subsidiaries omitted when consolidated statements are being filed.
• Auditor’s UDIN missing from the uploaded report.
• AGM date entered in the form does not match the notice or minutes.
• Directors’ Report annexures (AOC-2 for RPTs, Form MR-3 secretarial audit) forgotten.
• CSR-2 not filed alongside AOC-4 for CSR-applicable companies.

Closing action list

• Confirm your AOC-4 variant before the audit closes — variant drives disclosure format.
• Diarise the due date on the same calendar as the AGM.
• Complete DSC renewal for directors and CS at least 15 days before filing.
• Retain the SRN acknowledgement in the compliance file.

AOC-4 is a small filing with disproportionate downstream consequences. Get the variant right, coordinate with the auditor, and file within the thirty-day window — that discipline avoids most of the enforcement pain that follows.