Throughout the year
Object compliance
Track programmes, grants, donations and expenses against the Section 8 licence objects.
OngoingAnnual compliance calendar
Key filing windows for a Section 8 Company
Common timelines for a company with a 31 March financial year. AGM-linked dates must be calculated from the actual or statutory AGM date.
Section 8 compliance is more than annual forms. The company must continue applying income toward its licensed objects, avoid dividend distribution and maintain records that support charitable or not-for-profit use of funds.
30 June
DPT-3
Annual reporting of deposits and prescribed outstanding receipts, where applicable.
Conditional30 September
DIR-3 KYC
Annual KYC for DIN holders covered by Rule 12A.
DIN holder30 days after AGM
AOC-4
Financial statements, Board's Report, auditor's report and prescribed attachments.
Core filing60 days after AGM
MGT-7
Annual return covering members, directors, meetings and other company particulars.
Core filingCore governance
What Section 8 compliance includes beyond e-filing
ROC forms should be supported by properly approved accounts, meetings, disclosures, registers, licence compliance and signed records.
Board meetings
Convene Board meetings at the applicable frequency and record approvals for programmes, grants and operations.
- Notice, agenda and attendance
- Quorum and participation records
- Minutes and resolution tracking
Accounts and audit
Maintain books, prepare financial statements and complete statutory audit even where activity is grant-funded or non-commercial.
- Balance sheet and income/expenditure account
- Donation, grant and programme ledgers
- Notes, schedules and audit report
Annual General Meeting
Approve accounts and complete member business through a properly convened AGM within the applicable timeline.
- AGM notice and explanatory statement
- Attendance and voting records
- Minutes and adopted accounts
Object and licence review
Confirm that income, donations and activities are applied only toward permitted Section 8 objects.
- No dividend or member profit distribution
- Programme-wise fund utilisation
- Licence-condition review
Statutory registers
Keep registers and corporate records current at the registered office or other legally approved location.
- Members, directors and KMP
- Charges, loans and investments
- Contracts and beneficial ownership
Tax and donor records
Track tax, donor, grant and sectoral obligations based on registrations and funding sources.
- Income-tax return and audit
- 12A/80G/FCRA review where relevant
- CSR, GST and TDS applicability
ROC form checklist
Annual and conditional forms for Section 8 Companies
This table distinguishes core annual filings from licence-linked and conditional forms that become mandatory only when their legal trigger applies.
| Form / compliance | Standard timeline | Purpose | Applicability |
|---|---|---|---|
| AOC-4 / applicable variant | Generally within 30 days of AGM | File adopted financial statements, Board’s Report, auditor’s report and prescribed attachments. | Core annual filing |
| MGT-7 | Within 60 days of AGM or date AGM should have been held | Annual return containing ownership, directors, meetings and other prescribed particulars. | Unless eligible for MGT-7A |
| MGT-7A | Within prescribed annual-return timeline | Abridged annual return only where the company qualifies for the prescribed category. | Classification based |
| ADT-1 | Generally within 15 days of relevant AGM | Intimation of statutory auditor appointment or reappointment. | When appointment filing arises |
| DIR-3 KYC / WEB | 30 September for covered DIN holders | Update or confirm annual KYC of directors and other DIN holders. | DIN-holder compliance |
| DPT-3 | 30 June | Return of deposits and/or prescribed outstanding money or loan not considered deposits. | Receipt and exemption based |
| MSME Form I | 30 April and 31 October | Half-yearly reporting of prescribed outstanding dues to micro or small enterprise suppliers. | Specified companies only |
| MGT-14 | Within prescribed period from resolution | File specified Board or member resolutions, including object, MOA/AOA or major governance changes where required. | Resolution based |
| INC-20 / licence matters | Event/application based | Section 8 licence-related intimation, conversion or revocation-linked compliance where applicable. | Licence-event based |
| CSR-2 | As prescribed with/after annual financial filing | Report CSR particulars where the company itself is covered by Section 135. | Section 135 applicability |
Separate obligations: Income-tax exemption, 12A/80G, FCRA, CSR grant reporting, GST, TDS, labour-law, FEMA and sector-regulator filings are not replaced by MCA annual compliance.
Event-based compliance
File promptly when Section 8 particulars change
These filings arise from corporate decisions, licence-sensitive changes and transactions; they do not wait for the annual filing season.
Directors and KMP
- DIR-12 for appointment, resignation or designation change
- DIR-6 for changes in DIN particulars
- Update interest, eligibility and related-party records
Registered office
- INC-22 for office verification or change
- INC-23 where Regional Director approval is required
- Related resolutions and address evidence
Objects and activities
- Review whether new programmes fit Section 8 objects
- MGT-14 and approval records where objects change
- Licence-condition review before major shifts
Name, MOA and AOA
- Object-clause and articles amendments
- Member and Board approval documentation
- MCA approval where licence terms require it
Charges and borrowing
- CHG-1 / CHG-9 for creation or modification
- CHG-4 for satisfaction of charge
- Check lender and donor restrictions
Beneficial ownership
- BEN-2 following applicable BEN-1 declaration
- MGT-6 for beneficial-interest declarations
- Update statutory ownership registers
Working papers
Records commonly required for Section 8 compliance
Well-maintained programme, donor and governance records reduce filing errors and support compliance reviews.
Financial records
Trial balance, ledgers, bank statements, invoices, fixed assets, loans and reconciliations.
Programme records
Grant, donation, project, beneficiary and fund-utilisation records aligned with licensed objects.
Meeting records
Notices, agenda papers, attendance, resolutions, minutes and member approvals.
Licence and tax data
Section 8 licence, MOA/AOA, DIN KYC, auditor records, 12A/80G/FCRA details where applicable.
Frequently Asked Questions
Quick answers about Section 8 Company ROC and annual compliance.
Get Expert HelpIs annual compliance mandatory if the company has no business? +
Generally yes. An active Section 8 Company ordinarily continues to have annual accounts, audit and ROC filing obligations even when turnover or operations are nil.
Can a Section 8 Company distribute profit to members? +
No. A Section 8 Company must apply its income and profits toward its stated objects and cannot distribute dividend or profit to members.
Does every Section 8 Company file DPT-3 and MSME Form I? +
No. Each requires an applicability review based on outstanding receipts, exemptions and reportable dues to micro or small suppliers.
What happens when annual ROC forms are filed late? +
Additional fees and statutory penalties may arise. Continued default can affect directors, due diligence, banking, investment and other MCA applications.
Are AOC-4 and MGT-7 due dates always 30 October and 29 November? +
No. Those dates are common where the AGM is held on 30 September. The statutory filing period is calculated from the actual or required AGM date, subject to applicable rules and extensions.
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