In this guide · 10 sections
- Most Division I companies file AOC-4. AOC-4 XBRL applies to listed companies and their Indian subsidiaries, paid-up capital of ₹5 crore or more, turnover of ₹100 crore or more and Ind AS companies, and a company that has once filed in XBRL stays there. A small company can fall in this class.
- AOC-4 is due within 30 days of the AGM (s.137(1)); a One Person Company files within 180 days of the year end, which is 27 September 2026 for FY 2025-26.
- MCA General Circular 05/2026 (24 October 2026) allows the AOC-4 forms for FY 2025-26 up to 31 December 2026 and MGT-7 / MGT-7A up to 31 January 2027 without additional fee. It does not extend the AGM date, and a filing after the window pays from the original due date.
- Schedule III requires rounded statements, while the form asks for absolute rupees and has lines the statements do not show (managerial remuneration, payment to auditors, insurance, power and fuel; domestic and export turnover). Keep a line-by-line tie-out before anyone opens the form.
- Check the pre-filled previous-year figures against this year's comparatives, and the auditor, signatory and date details against the signed documents. The director declares that the auditor's report extract is in line with the report.
Try SignReady: Draft Schedule III statements from the trial balance, with previous-year figures and linked notes.
Start freeThe accounts are signed in lakhs. Then someone opens AOC-4 and finds that it wants rupees, that last year's figures are already filled in and no longer match the comparatives, and that it has a line for payment to auditors which the Statement of Profit and Loss never showed. The AGM date is gone and the partner is asked to look at a form that does not visibly agree with the signed statements. This guide covers which form applies, the due dates, the attachments, how Schedule III headings map to the form, where differences come from, and what to check before the DSC goes on. Law as at 31 October 2026; figures are illustrative. Form headings below are from AOC-4 as notified in G.S.R. 357(E), in force from 14 July 2025. We do not quote field numbers, because the portal and its instruction kit are the place to confirm those.
Who files, and on which form
Every company files its financial statements with the Registrar under s.137, on the form rule 12 of the Companies (Accounts) Rules, 2014 and the XBRL Rules, 2015 point to.
| Form | Who uses it | Point to watch |
|---|---|---|
| AOC-4 | Companies outside the XBRL class, which covers most small private companies | Has its own linked forms and extracts (see below) |
| AOC-4 XBRL | Listed companies and their Indian subsidiaries; paid-up capital ₹5 crore or more; turnover ₹100 crore or more; companies required to follow Ind AS (rule 3(1), XBRL Rules, 2015) | Once filed in XBRL, the company continues in XBRL even if it later falls below the limits (rule 3(2)). NBFCs, housing finance, banking and insurance companies are outside these rules |
| AOC-4 CFS | A company whose parent form says consolidated statements are required | It remains a separate form that asks for the SRN of the standalone AOC-4. MCA's FAQ says it is filed as a linked form, and independently only where the standalone was filed on V2 |
| AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS) | NBFCs on Ind AS | Outside the scope of this guide |
The small company trap. The small company limits are now ₹10 crore capital and ₹100 crore turnover (G.S.R. 880(E), from 1 December 2025; see the new limits). Rule 3 has no carve-out for small companies, so a small company with ₹6 crore paid-up capital is in the XBRL class, and stays there. Check last year's filing form before assuming plain AOC-4. An older MCA XBRL FAQ counts turnover gross of duties and taxes for the ₹100 crore test; confirm it for a company near the line.
Small company and OPC specifics. Neither has to include a cash flow statement in its financial statements (proviso to s.2(40)). Both can use the shorter Board's report under rule 8A. The extract of the Board's report asks whether the company is an OPC or small company at the year end. MCA's FAQ adds that where a small company or holding / subsidiary status changed in the year, AOC-4 is filed first to update the flag and MGT-7 afterwards. A One Person Company holds no AGM, its statements are signed by one director (s.134(1)), and it files them as adopted by the member.
The due date, and what Circular 05/2026 changes
| Situation | Due date | FY 2025-26 example |
|---|---|---|
| Adopted at the AGM | 30 days from the AGM (s.137(1)) | AGM 30 September 2026: 30 October 2026 |
| Not adopted at the AGM | Unadopted statements within 30 days of the AGM, taken on record as provisional; adopted statements within 30 days of the adjourned AGM (provisos to s.137(1)) | Form field "Nature of financial statements"; the later filing quotes the earlier SRN |
| AGM not held | Within 30 days of the last date for the AGM, with a statement of the facts and reasons (s.137(2)) | Last date 30 September 2026: 30 October 2026 |
| One Person Company | 180 days from the close of the year (s.137(1) proviso) | 27 September 2026 |
General Circular 05/2026 (File No. Policy-17/111/2022-CL-V-MCA, 24 October 2026) covers these points:
- Forms and dates. AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) up to 31 December 2026; MGT-7 and MGT-7A up to 31 January 2027; no additional fee.
- Year. FY 2025-26 only. Earlier years are not covered.
- Not an AGM extension. The circular says so expressly, and companies that missed statutory timelines stay liable under the Act.
- After the window. All fees, including additional fees, apply from the date the filing was originally due, not from 1 January.
The circular does not list ADT-1, MGT-14 or other forms, so those keep their own dates (CRA-4 has separate relief, General Circular 06/2026 of 27 October 2026). The normal filing fee is still payable. Where an AGM validly held later gives a s.137 date after 31 December, the circular does not shorten it; that is our reading, so check it against the circular on the MCA site for an unusual case. Add the date to your file calendar now, as the audit season workflow suggests.
What goes with the form
V3 changed the shape of the filing more than the content. Under rule 12(1C), the extracts are e-forms filed along with AOC-4. MCA's FAQ sets the sequence of linked filings for AOC-4:
| Item | When |
|---|---|
| Copy of statements authenticated under s.134, including the auditor's report and other documents (PDF, 2 MB on the notified form) | Always |
| Extract of Board Report | Mandatory linked form |
| Extract of Auditor's Report (Standalone) | Mandatory linked form. Keys in opinion, basis, emphasis of matter, key audit matters, qualifications, clause-wise CARO comments, internal financial controls |
| AOC-4 CFS and Extract of Auditor's Report (Consolidated) | Where consolidated statements are required |
| e-Form AOC-1 | A subsidiary, associate or joint venture exists |
| e-Form AOC-2 | "Yes" to related party transactions in the parent form |
| CSR-2 | s.135 applies, or there is unspent CSR from the previous three years |
| Secretarial Audit Report; supplementary or test audit report; CAG comments | Where applicable |
| Statement of facts and reasons for not adopting the statements, or for not holding the AGM | Where applicable |
XBRL filers. Rule 3(1A) requires a signed PDF of the authenticated statements, with the Board's and auditors' reports, attached to AOC-4 XBRL. MCA's FAQ says only CSR-2 can be linked to AOC-4 XBRL, though rule 12(1C) reads more widely; check on the portal when you file.
SignReady drafts Schedule III statements from the Excel trial balance as an editable Excel workbook, with previous-year figures and formulas linking the notes to the statements, and FinalCheck lists the arithmetic and cross-reference differences it finds. It does not prepare or file AOC-4.
Schedule III lines mapped to the form
The balance sheet in the form's Segment I follows the Division I face closely. The P&L in Segment II does not.
| Statement line | Where it goes in AOC-4 | Check |
|---|---|---|
| Share capital; reserves and surplus; share warrants; share application money | Part B, same headings. Share capital movement table; financial parameters | Movement table closes to the note. MCA's FAQ says paid-up capital is updated through MGT-7 / 7A, not AOC-4 |
| Long-term and short-term borrowings | Part B face. Break-up tables are for unsecured borrowings only; "Secured Loan" is a parameter | Unsecured break-up + secured = face. No break-up line for current maturities |
| Trade payables | Two lines: micro and small enterprises; others | Agrees to the MSME note |
| Other long-term liabilities; provisions; other current liabilities; deferred tax | Same headings | Deferred tax on the same side (asset or liability) as the face |
| PPE and intangible assets, CWIP, intangibles under development | Four sub-lines; gross value and depreciation also as parameters | Parameter agrees to the PPE note, not the net figure |
| Long-term loans and advances | Face, plus separate tables for unsecured good and doubtful | Net of provision, plus any secured loans (the tables cover unsecured only), agrees to the face |
| Trade receivables | Face, plus table: secured good, unsecured good, doubtful, provision, net, due by directors or officers | Net agrees to the face and the ageing note |
| Investments, inventories, cash and cash equivalents, other assets | Same headings | Current and non-current split as signed |
| Revenue from operations | Domestic and export, each split into goods manufactured, goods traded, services | The notified form has no line for other operating revenues (note heading). Confirm the placing and record it |
| Other income | Dividend, interest, net gain or loss on investments, other non-operating income | Agrees to the note total |
| Materials, purchases, changes in inventories | Same headings; changes split into finished goods, WIP, stock-in-trade | Split agrees to the note |
| Employee benefits; other expenses | Adds managerial remuneration, payment to auditors, insurance, power and fuel as lines of their own | Total expenses unchanged (example below) |
| Exceptional and extraordinary items; tax | Same lines; tax shows current and deferred only | Earlier-year tax shown separately in the statements needs a recorded placing |
| Earnings per share | Before and after extraordinary items; again as a parameter | Same as the AS 20 note |
Several form items are on no statement face: net worth (s.2(57), so revaluation reserves are out), unpaid dividend, deposits, foreign exchange earnings and spending, rent paid, product and service codes, cost records. Collect them when the notes are prepared. If a mapping is unclear, the instruction kit for the current version decides.
How the mismatches arise
1. Rounding. Schedule III requires statements rounded to a chosen unit (the format and rounding rules). The form says absolute rupees, not hundreds, thousands or lakhs. So the two will not look alike even when both are right:
| Line | Form (₹, from the final TB) | Signed statement (₹ lakh) |
|---|---|---|
| Share capital | 25,00,000 | 25.00 |
| Reserves and surplus | 1,84,36,420 | 184.36 |
| Long-term borrowings | 62,18,430 | 62.18 |
| Trade payables (others) | 48,07,365 | 48.07 |
| Other current liabilities | 9,12,840 | 9.13 |
| Short-term provisions | 6,24,315 | 6.24 |
| Total | 3,34,99,370 | 334.98 |
₹3,34,99,370 is 334.99 lakh, while the statement adds its rounded lines to 334.98. That 0.01 is rounding, not an error. Multiplying 184.36 by one lakh and keying ₹1,84,36,000 is the habit to stop: it invents a figure that is in no ledger and is rounded in the way the form forbids. Key the rupees from the final trial balance and keep the tie-out sheet: form line, statement line, difference. Any difference above the rounding unit needs a reason.
2. Lines the statements do not have. With other expenses ₹18,40,000 and employee benefits ₹32,00,000 (including directors' remuneration ₹12,00,000):
| Form line | ₹ |
|---|---|
| Employee benefit expenses (32,00,000 − 12,00,000) | 20,00,000 |
| Managerial remuneration | 12,00,000 |
| Payment to auditors | 75,000 |
| Insurance expenses | 1,10,000 |
| Power and fuel | 3,40,000 |
| Other expenses (18,40,000 − 75,000 − 1,10,000 − 3,40,000) | 13,15,000 |
| Total, equal to 32,00,000 + 18,40,000 | 50,40,000 |
The amounts come from the same split you need for the other expenses note. Keying the note total against "other expenses" and then the auditors' fee again counts it twice.
3. Previous-year regrouping. Previous-year balance sheet and P&L figures come pre-filled from last year's filing. If this year's comparatives were regrouped, they differ. Say ₹5,00,000 of current maturities moved from long-term to short-term borrowings: last year's form shows ₹40,00,000 and ₹6,00,000, this year's comparatives ₹35,00,000 and ₹11,00,000, and the total stays ₹46,00,000. MCA's FAQ says the pre-filled figures are editable, and that the reason column is not mandatory. Fill it anyway, since the next reader will ask. The statements should carry the same regrouping (regrouping previous-year figures). MCA also says trade payables and other income do not pre-fill where last year's filing was on V2.
4. Validation. The form checks what you key against what MCA holds. MCA's FAQ says the SRNs entered (ADT-1, INC-28, AOC-4, MGT-14, GNL-1, wherever applicable) must be approved and associated with the company, and an adopted filing after an adjourned AGM must quote an SRN filed for provisional statements. Class and category pre-fill on today's position and are editable, which matters where status changed after the year end. We have not listed arithmetic validations, because the kit and the portal are the source for those, and they can change. An error message is a reason to recheck the figure against the statements, not to adjust it until it clears.
What the auditor's and directors' details must match
| In the form | Agree it to |
|---|---|
| Date of Board meeting approving the statements; date of Board meeting approving the Board's report | Minutes, and the date on the signed statements |
| Signatories: DIN or PAN, name, designation, date of signing | The signature block, including who actually signed (who signs under s.134) |
| SRN of ADT-1, number of auditors | The approved ADT-1 for the auditor who signed. MCA's FAQ points to "Check Annual filing Status" for a lost SRN |
| Auditor or firm PAN, category, membership or firm registration number, name, address; signing member's name and membership number | The audit report signature block and firm records |
| Date of signing of reports by the auditors | Report date, on or after the Board's approval |
| AGM held, date, due date, extension, GNL-1 SRN | Notice, minutes and the Registrar's approval |
| Holding and subsidiary details; consolidation required | Share register, and the AOC-1 and CFS position |
| Extract of Auditor's Report: every field, and CARO applicable yes or no | The signed report. The director declares the extract is in line with it, so paste from the final report and not a draft |
The notified form shows no UDIN field, so the UDIN stays on the report itself. The form also has a declaration citing the Board resolution authorising the signatory, and a certificate block for a practising CA, CS or cost accountant, who states the particulars were verified from the original records and accepts s.448 exposure. Read it before signing as that professional. A firm tracking the date can use SignReady's Key dates, which show the AOC-4 date as a reminder and can be marked done with the SRN; SignReady does not prepare or file the form.
Late filing: additional fee and penalty
- Additional fee. ₹100 per day, per form, with no upper limit, for forms under ss.92 and 137 (s.403(1), first proviso, not less than ₹100 a day; MCA applied this from 1 July 2018). The multiple-of-fee table in G.S.R. 12(E) excludes these forms. Section 403 also has a proviso on repeat defaults, so check what the portal computes for a repeat defaulter.
- Example. AGM 30 September 2026, due 30 October 2026. Filed by 31 December 2026: no additional fee. Filed on 12 January 2027: the window is lost and the clock runs from 30 October, 74 days × ₹100 = about ₹7,400, plus the normal fee.
- Penalty under s.137(3). The company: ₹10,000 plus ₹100 per day of continuing failure, up to ₹2 lakh. The managing director and CFO (or the other persons the sub-section names): ₹10,000 plus ₹100 per day, up to ₹50,000. Section 403(2) keeps penalties alive alongside fees. The circular speaks of additional fees and "extension of time for filing" in its subject; it does not mention s.137(3), and it keeps liability for AGM defaults.
- Directors. Failure to file financial statements or annual returns for a continuous period of three financial years disqualifies directors under s.164(2)(a).
Pre-filing checklist
- Confirm the form: last year's SRN and form type, paid-up capital, turnover, any XBRL history.
- Confirm the date: AGM, adjourned AGM or OPC date, and whether the FY 2025-26 window still helps.
- Check that the statements attached are the signed ones, with reports, within the size limit. The 7 checks before signing should already be done.
- Prepare the tie-out: every form line, statement line, note, difference. Totals agree to the rupee in the form, and to within rounding against the statements.
- Compare pre-filled previous-year figures with comparatives and record each change.
- Agree auditor, signatory and AGM details to the source documents.
- Check the extracts against the signed Board's and auditor's reports, clause by clause for CARO.
- Answer the triggers correctly: consolidation, related parties, subsidiary or associate, CSR, secretarial audit. Each one opens a linked form.
- Download the filed form and file the SRN and challan in the audit or secretarial file.
Try SignReady: Key dates show the AOC-4 date as a reminder; mark it done with the SRN. SignReady does not file forms.
Start freeFrequently asked questions
What is the due date for AOC-4 for FY 2025-26?
By statute, 30 days from the AGM, so 30 October 2026 for an AGM on 30 September 2026, and 27 September 2026 for a One Person Company. MCA General Circular 05/2026 allows filing for FY 2025-26 up to 31 December 2026 without additional fee. It does not extend the AGM date.
What does MCA General Circular 05/2026 cover?
Financial statements for FY 2025-26 in AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) up to 31 December 2026, and annual returns in MGT-7 and MGT-7A up to 31 January 2027, without additional fee. A filing after that pays additional fees from the original due date. Earlier years and other forms are not listed.
Who has to file AOC-4 XBRL?
Companies listed in India and their Indian subsidiaries, companies with paid-up capital of ₹5 crore or more, companies with turnover of ₹100 crore or more, and companies required to follow Ind AS. NBFCs, housing finance, banking and insurance companies are outside the XBRL Rules. A company that has once filed in XBRL continues to do so even if it falls below the limits.
Does a small company with ₹6 crore paid-up capital need XBRL?
Yes. Rule 3 of the XBRL Rules, 2015 has no exception for small companies, so paid-up capital of ₹5 crore or more brings it into AOC-4 XBRL even though the small company limit is now ₹10 crore capital and ₹100 crore turnover.
Should AOC-4 figures be in lakhs like the balance sheet?
No. The form says figures go in absolute rupees and should not be rounded to hundreds, thousands, lakhs or crores. Key the rupee figures from the final trial balance and keep a sheet tying each form line to the rounded statement line, so that small rounding differences are explained.
How much is the late fee for AOC-4?
An additional fee of ₹100 per day with no upper limit, plus the normal fee, under s.403. For FY 2025-26, none applies if filed by 31 December 2026 under General Circular 05/2026, but after that date it runs from the original due date. Penalties under s.137(3) are separate: for the company, ₹10,000 plus ₹100 per day up to ₹2 lakh.
Sources
- MCA — General Circular No. 05/2026, File No. Policy-17/111/2022-CL-V-MCA, 24 October 2026 (the MCA copy could not be opened directly; read through its indexed text and the reproduction below)
- TaxGuru — text of General Circular No. 05/2026
- CorpLawUpdates — General Circular No. 06/2026 on CRA-4, 27 October 2026 (secondary; MCA copy not opened)
- Companies (Accounts) Second Amendment Rules, 2025 — G.S.R. 357(E), 30 May 2025 (Gazette copy): rule 12(1C), Forms AOC-4, AOC-4 CFS, extracts
- XBRL Amendment Rules, 2025 — G.S.R. 371(E), 6 June 2025
- Companies (Filing of Documents and Forms in XBRL) Rules, 2015 — rule 3, as amended
- Companies Act, 2013 — section 137, as amended
- Companies Act, 2013 — section 403, as amended
- Companies (Registration Offices and Fees) Amendment Rules, 2022 — G.S.R. 12(E), 11 January 2022 (Gazette copy)
- MCA — FAQs for Annual Filing: AOC-4 and linked filings; Commonly Asked Questions (read through indexed text)
- MCA — XBRL Policy Specific FAQs (older; read through indexed text)
- ICAI — announcement of 30 December 2025 on MCA General Circulars 06/2025 and 08/2025 (FY 2024-25)
- Companies Act, 2013 — sections 2(40), 2(57), 134(1), 164(2)(a); Companies (Accounts) Rules, 2014, rules 8A and 12
- Small company limits — G.S.R. 880(E), 1 December 2025 (Gazette)
In SignReady, the draft statements from the trial balance, FinalCheck, client queries and review points sit in one finalisation, and Key dates show the AOC-4 date as a reminder. Filing stays with the company. First 3 finalisations free.
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Version history: 31 Oct 2026 — first published.
