The Institute of Company Secretaries of India (ICSI) submitted a representation to the Ministry of Corporate Affairs highlighting persistent technical and practical issues faced by stakeholders on the MCA-21 V3 portal. The representation acknowledged the Government’s efforts toward digital governance and ease of compliance but emphasized that recurring system glitches are causing filing inefficiencies and unintended non-compliances. Key concerns raised included loss of saved drafts due to session timeouts, attachment upload failures arising from file-size restrictions and system glitches, login and “Switch User” functionality errors, inability to edit forms such as AOC-4 and SH-7 after submission, limited access to public documents, mandatory login requirements for viewing company master data, and restrictive address character limits in SPICe+ forms. ICSI recommended multiple corrective measures including auto-save draft facilities, improved login resolution systems, editable e-forms, expanded attachment limits, easier access to master data, and enhanced portal functionality to reduce compliance burdens and improve stakeholder confidence.
THE INSTITUTE OF
Company Secretaries of India
IN PURSUIT OF PROFESSIONAL EXCELLENCE
Statutory body under an Act of Parliament
(Under the jurisdiction of Ministry of Corporate Affairs)
G&CL: MCA: MAY:2026 | Dated: 6th May 2026
Ms. Deepti Gaur Mukerjee
Hon’ ble Secretary
Ministry of Corporate Affairs
Government of India
New Delhi
Respected Madam,
Subject: Functioning of MCA-21 V3 Portal – Issues and Challenges faced by stakeholders – Reg.
Greetings from the Institute of Company Secretaries of India!
At the outset, we sincerely appreciate the initiatives undertaken by the Ministry of Corporate Affairs (MCA) in implementing the MCA V3 portal, aimed at enhancing digital governance, transparency, and ease of compliance.
However, pursuant to feedback received from our members and other stakeholders, several practical and technical challenges are being encountered while using the MCA Portal and MCA-21 V3 portal. These issues are impacting the efficiency of filings, and are leading to unintended non-compliances.
In this regard, we wish to submit the following key issues along with our suggestions:
Issues
Users frequently face challenges in retrieving saved drafts or experience loss of data due to session timeouts.
The stakeholders have informed on frequent failures in uploading attachments due to size restrictions, format limitations, and system glitches.
Frequent login-related issues are being encountered by stakeholders, particularly in relation to the “Switch User” functionality. Users are unable to update their profile status (e.g., from ACS to FCS). Additionally, while creating User IDs, generic system errors such as “Something went wrong” are frequently encountered.
| Form/Difficulty | Issues | Suggestions |
| Lack of Draft Saving and Retrieval Efficiency | Users frequently face challenges in retrieving saved drafts or experience loss of data due to session timeouts. | Introduce a robust draft management system with auto-save and easy retrieval options. |
| Issues in Uploading Attachments | The stakeholders have informed on frequent failures in uploading attachments due to size restrictions, format limitations, and system glitches. | Increase the attachment size limit for better readability. |
| MCA 21 V3 Login Issues | Frequent login-related issues are being encountered by stakeholders, particularly in relation to the “Switch User” functionality. Users are unable to update their profile status (e.g., from ACS to FCS). Additionally, while creating User IDs, generic system errors such as “Something went wrong” are frequently encountered. | Have robust system for resolution of login related issues. |
| Limited Data on View Public Documents | At present, complete data of forms which are filed by the company with registrar is not available on the MCA portal under the “View Public Documents” tab. | It is suggested that a facility may be provided to companies, possibly on a payment basis, to enable them to identify, at the click of a button, the years for which filings are pending. |
| Mandatory Login Requirement for Viewing MCA Master Data | At present, users are required to login to access basic company master data on the MCA portal. This creates unnecessary inconvenience, particularly in situations where professionals, stakeholders, or third parties need to quickly verify company details. This creates unnecessary friction, particularly where quick verification of company details is required by professionals, stakeholders, and third parties. | It is suggested that access to basic company master data may be made available without mandatory login (as was the practice earlier), while continuing to restrict access to sensitive or detailed information behind login credentials. |
| Non-Editable Nature of e-Form AOC-4 | Form AOC-4 is not easily editable once prepared or saved. Even minor modifications require the form to be re-filled and revalidated, along with repeated uploading of attachments. This results in duplication of effort, increased time consumption, and a higher likelihood of clerical errors. | An edit functionality may be introduced for saved drafts, enabling users to make necessary revisions without requiring complete re-preparation of the form. |
| No Edit Option for Form SH-7 | Post submission of Form SH-7, if any minor correction or modification is required, whether in the form itself or in the linked e-MOA/e-AOA, there is currently no provision available under the “My Applications” section to make such changes. Stakeholders are consequently required to cancel the entire SRN and re-file all related forms. | An “Edit” option may be introduced to facilitate minor corrections in submitted e-forms and their linked forms, thereby avoiding unnecessary duplication of filings. |
| Insufficient Character Limit for Address Fields in SPICe+ Forms | The address fields in SPICe+ forms have restrictive character limits. This creates practical difficulties, particularly for entities located in metropolitan areas, where complete and accurate registered office addresses cannot be fully captured, leading to abbreviations or incomplete disclosures. | The character limit for address fields may be enhanced to allow complete and accurate entry of address details in line with practical requirements. |
In light of the above, we humbly request the Ministry to consider the issues highlighted and take necessary steps to address them on priority. Addressing these concerns will significantly enhance user confidence, reduce compliance burden, and further the objectives of the MCA V3 initiative.
We shall be happy to provide any further information or clarification that may be desired in this regard.
Thanking you
Yours faithfully
(CS Pawan G. Chandak)
President
The Institute of Company Secretaries of India
