Summary: The Institute of Company Secretaries of India (ICSI), through its representation dated 9 October 2026, has requested the Ministry of Corporate Affairs (MCA) to extend the due dates for filing annual e-forms under the Companies Act, 2013, up to 31 December 2026 without levying additional fees. The request follows numerous stakeholder representations concerning persistent technical difficulties on the MCA-21 V3 portal, including downtime, slow response times, session timeouts, login problems, incorrect pre-filled information, Digital Signature Certificate association failures, validation errors, payment processing difficulties and problems accessing filed documents. ICSI has also highlighted the increased compliance burden resulting from migration to revised annual filing forms, particularly AOC-4 and MGT-7, which now require more extensive data entry and disclosures. XBRL-related tagging, validation and reconciliation requirements have further increased preparation time. According to the Institute, heavy portal traffic during working hours frequently disrupts statutory filings. Referring to CBDT Circular No. 07/2026 dated 28 September 2026, which extended specified income-tax return and audit-report filing deadlines, ICSI has sought similar relief for corporate filings. The requested extension covers AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), DIR-12, ADT-1, MGT-7 and MGT-7A. ICSI has urged the Ministry to grant a one-time extension to facilitate accurate and complete compliance while supporting Ease of Doing Business. The representation constitutes a request, and does not itself extend any statutory filing deadline.
THE INSTITUTE OF COMPANY SECRETARIES OF INDIA
G&CL: MCA: OCT:01/2026 | Dated: October 09, 2026
Dr. Pallavi Jain Govil
Secretary
Ministry of Corporate Affairs
Government of India
Respected Madam,
Subject: Request for Extension of Due Dates for Filing Annual E-Forms under the Companies Act, 2013 till 31.12.2026 without Levy of Additional Fees
Greetings from the Institute of Company Secretaries of India!
The ICSI conveys its sincere appreciation for the continuous efforts of the Ministry of Corporate Affairs towards strengthening the corporate regulatory framework and enhancing Ease of Doing Business through regulatory reforms and technological advancements under the MCA-21 V3 platform.
However, the Institute has been receiving numerous representations from the stakeholders regarding persistent difficulties being experienced in filing Annual e-forms on the MCA-21 V3 portal. Following are the key concerns being raised by the stakeholders:-
1. Persistent Technical Issues on MCA-21 V3 Portal, including:
- Frequent portal downtime and slow response time.
- Session timeout and automatic logout during form preparation and filing.
- Difficulties in login, profile updation and user access management.
- Errors in pre-filled data and inconsistencies in data retrieval.
- Challenges in associating Digital Signature Certificates (DSCs).
- Form validation failures despite correct data entry.
- SRN generation, payment processing and challan-related issues.
- Difficulties in viewing, downloading and tracking filed forms and approvals.
2. Migration to Revised Annual Filing Forms: The transition of annual filing forms to the V3 framework has introduced significant structural and disclosure changes. Forms such as AOC-4 and MGT-7 now require extensive data capturing within the forms themselves, reducing reliance on attachments and increasing preparation time.
3. Practical Difficulties in Annual Filing and XBRL Compliance: Preparation and filing of annual financial statements and annual returns, particularly XBRL filings, involve extensive tagging, validation and reconciliation requirements. The additional time required for accurate reporting is further compounded by portal-related challenges.
4. Portal Overload During Working Hours: During peak hours, especially between 11 a.m. to 6 p.m., the system frequently crashes or becomes inaccessible due to heavy concurrent traffic, causing disruption in time-bound filings.
Further it is respectfully submitted that the Central Board of Direct Taxes (CBDT), recognizing the practical challenges faced by stakeholders in meeting statutory compliance requirements, vide Circular No. 07/2026 dated 28 September 2026, extended the due date for furnishing Income Tax Returns in audit cases for Assessment Year 2026-27 from 31 October 2026 to 21 November 2026, and correspondingly extended the timeline for submission of audit reports from 30 September 2026 to 21 October 2026.
ICSI Submission:
In view of the above circumstances, and on behalf of the stakeholders, we most respectfully submit for Ministry’s kind consideration for providing extension of due dates for all annual filing forms AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), DIR-12, ADT-1, MGT-7, and MGT-7A – till December 31, 2026, without levy of additional fees.
Considering the continuing technical challenges on the MCA-21 V3 portal, the increased complexity of annual filing forms, enhanced disclosure requirements and the recent precedent of extensions granted by the Central Board of Direct Taxes, a one-time extension up to 31 December 2026 would provide substantial relief to companies and professionals while ensuring accurate, complete and quality compliance.
The Institute shall remain grateful for a favourable consideration of this request in the larger interest of stakeholders and in furtherance of the Government’s objective of promoting Ease of Doing Business and Ease of Compliance.
We will be pleased to furnish any additional information/clarification required in this matter.
Thanking you,
Yours faithfully,
(CS Asish Mohan)
Secretary
The Institute of Company Secretaries of India
CC: Smt. Anita Shah Akella, Joint Secretary, MCA
