Summary: The upcoming months of September, October, and November 2024 are critical for companies and LLPs in India, as they must meet several important ROC filing deadlines under the Companies Act and LLP Act. These months include key dates for holding Annual General Meetings (AGMs), finalizing financial statements, and filing essential forms with the Registrar of Companies (ROC). Notable deadlines include the filing of AOC-4 for financial statements, ADT-1 for auditor appointments, and MGT-7 for annual returns. Additionally, forms such as DIR-3 KYC for DIN holders and LLP-8 for LLPs’ solvency statements must be submitted by their respective due dates. Delays in filing can result in penalties and additional fees, as the Ministry of Corporate Affairs is strictly enforcing compliance. Companies should ensure timely submissions to avoid any legal or financial repercussions. This editorial highlights these essential due dates, helping companies stay compliant with ROC filing requirements during this crucial period.
SHORT SUMMARY:
In this editorial, the author shall discuss the due dates of ROC forms in relation to the Companies Act and LLP Act in the months of September, October, and November 2024.
These three months are very crucial from the point of view of corporations. In these months, Companies have to hold their Annual General Meetings, finalize their financial statements, and file the annual forms with Roc.
Every Company should complete the filing of forms with ROC on or before the due dates. These days, the Ministry is very strict about delays in filing the forms. Delay in filing any form can cause additional fees as well as a penalty or fine for the Company.
Note: In this editorial, we have taken the base AGM date as September 30, 2024.
MONTH WISE DUE DATE CALENDAR:
| S. No. | Type of Company | Form No | Purpose | Due Date |
| SEPTEMBER-2024 | ||||
| 1. | OPC | AOC-4 | Filing of Financial Statement | 27-Sep-2024 |
| 2. | Company on which Cost Audit Applicable | CRA-2 | Appointment of Cost Auditor | 28-Sept-2024 |
| Due Date for CRA-2 is 30 days from the date of BM or 180 from 1st April. Whichever is earlier. | ||||
| 3. | CRA-3 | Submission of Report of Cost Audit by the Auditor to Company | 28-Sept-2024 | |
| The Cost Auditor must submit his report to the Company within 180 days. from the end of financial year. | ||||
| 4. | All DIN Holders | DIR-3 KYC
(Web/ Form) |
KYC of person holding DIN as on 31-Mar-2024 | 30-Sept-2024 |
| 5. | Foreign Company | FC-3 | Annual Account of Foreign Company | 30-Sept-2024 |
| OCTOBER -2024 | ||||
| 6. | OPC | ADT-1 | Appointment of Auditor | 11-Oct-2024 |
| In case of OPC Due Date of AGM is 27-Sept-2024 therefore due date of ADT-1 shall be calculated accordingly. | ||||
| 7. | Other Companies | ADT-1 | Appointment of Auditor | 14-Oct-2024 |
| ADT-1 required to file with ROC within 15 days from the in this editorial we have take Base Date of AGM as 30-Sept-2024. | ||||
| 8. | Cost Audit | CRA-4 | Filing of Cost Audit Report | 27-Oct-2024 |
| The Cost Audit report must submit with ROC within 30 days from receipt of report. | ||||
| 9. | All Companies | AOC-4 | Filing of Financial Statement | 29-Oct-2024 |
| Due Date of AOC-4 CFS, AOC-4 XBRL all are same as mentioned above. With in 30 days of AGM. | ||||
| 10. | Companies on which CSR applicable | CSR-2 | Reporting of CSR Contribution | 29-Oct-2024 |
| Due Date of CSR-2 is same as AOC-4. As this is addendum to AOC-4 | ||||
| 11. | OPC | DIR-12 | Regularization of Additional Director, if any | 27-Oct-2024 |
| 12. | All Companies | MGT-14 | Filing of AGM resolution with ROC | 29-Oct-2024 |
| In case of any special resolution passed or AGM held through Video Conferencing. | ||||
| 13. | All Companies | DIR-12 | Regularization of Additional Director | 30-Oct-2024 |
| 14. | LLP | LLP-8 | Statement of Account & Solvency | 30-Oct-2024 |
| 15. | All Companies | MSME-1 | Details of Pending payment to MSME Vendors | 31-Oct-2024 |
| NOVEMBER -2024 | ||||
| 16. | OPC | MGT-7A | Annual Return | 26-Nov-2024 |
| Within 60 from the Due Date of AGM. In case OPC Due Date of AGM is 27-Sept-2024. | ||||
| 17. | Other Companies | MGT-7 / MGT-7A | Annual Return | 29-Nov-2024 |
| 18. | Unlisted Public Companies | PAS-6 | Reconciliation of Share Capital Audit | 29-Nov-2024 |
| 19. | Entities Covered in Clause 3(1)(a) to 3(1)(e) of NFRA Rules 2018 | NFRA-2 | Annual return filed by Statutory Auditor with the (NFRA) respect of entities covered in Clause 3(1)(a) to 3(1)(e) of NFRA Rules 2018. | 30-Nov-2024 |
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Author – CS Divesh Goyal, GOYAL DIVESH & ASSOCIATES Company Secretary in Practice from Delhi and can be contacted at [email protected]).
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