A statutory professional body has formally written to the Ministry of Corporate Affairs acknowledging the extension of the annual filing deadline to 31 December 2025 but highlighting that persistent technical failures on the MCA-21 V3 portal continue to severely disrupt statutory filings under the Companies Act, 2013. Despite the extension, professionals are facing repeated errors across key annual forms such as AOC-4, AOC-4 XBRL, MGT-7 and MGT-7A, including validation failures, incorrect prefilled data, inability to upload Excel templates, SRNs not being generated or accepted, and system-generated contradictions between forms. In addition, frequent portal slowdowns, timeouts, non-functional access during peak hours, mandatory Excel-based workflows, and unexplained cancellation of SRNs have substantially increased compliance time and rework. The letter urges urgent technical remediation of the portal or, alternatively, a further extension of annual filing deadlines up to 31 March 2026 to ensure orderly and effective statutory compliance.
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 Afairs)
December 20, 2025
MCA:CL:DEC/2025
Ms. Deepti Gaur Mukerjee
Secretary
Ministry of Corporate Affairs
Government of India
Shastri Bhawan
New Delhi — 110 001
Subject: Functioning of MCA- 21 V3 Portal — Issues and Challenges faced by stakeholders — Reg.
Respected Madam,
We extend our sincere gratitude to the Ministry of Corporate Affairs for granting an extension of the annual filing deadline until 31st December 2025. This considerate decision has provided much-needed relief to professionals and companies facing challenges due to technical issues on the MCA portal.
However, we respectfully wish to bring to your kind attention that persistent and widespread technical difficulties continue to be encountered on the MCA portal during the annual filing process, even after the extension, making it difficult to file the e-Forms as required under the Companies Act, 2013.
Some of these issues and concerns are outlined below for your kind consideration:
ISSUES AND CIIALLENGES FACED BY PROFESSIONAL
| Form/Difficulty | Issues / Challenges |
|
AOC-4 |
|
| AOC-4 XBRL |
|
| MGT-7 |
|
| MGT-7A |
|
Further other common issues as notified by the professional s are mentioned below:
1. Frequent Slowdowns and Timeouts
The MCA portal continues to experience repeated slowdowns, timeouts, and performance degradation, particularly during peak filing hours between 3:00 p.m. and 8:00 p.m. It is frequently slow, unresponsive, or completely inaccessible during these periods, severely impacting productivity. Notably, even 15 days prior to the statutory due date, the MCA website has not been functioning properly, causing significant inconvenience to stakeholders.
2. Non-functional Website Access
On numerous occasions, the MCA website remains largely non-functional; even the home page fails to load, rendering filings impossible. Where access is available, filings are disrupted by frequent system errors, timeouts, and crashes, resulting in failed or incomplete submissions.
3. Additional Requirements under V-3 Portal
The V-3 portal has introduced mandatory Excel template uploads and other procedural changes, significantly increasing preparation time and complexity without commensurate facilitation. Even minor modifications necessitate saving and validating all linked forms afresh, requiring AOC-4 to be processed end-to-end each time. This has made the process unduly time-consuming, without any commensurate value addition for stakeholders.
4. Cancellation of SRNs
SRNs are being cancelled even for duly uploaded forms pending DSC affixation. Professionals are compelled to restart the entire filing process, leading to duplication of work, confusion, and avoidable delays. No clear guidance is provided regarding reasons for cancellation or corrective measures.
In view of the above, we respectfully request that necessary steps be taken to resolve the aforementioned issues at the earliest to enable smooth annual filing of e-Forms. Alternatively, we request that the due date for annual filings be extended up to 31st March 2026, thereby allowing stakeholders to complete statutory compliances.
We sincerely thank you for your continued support and consistent efforts toward promoting ease of doing business and streamlining compliance procedures. We shall be pleased to provide any further information or assistance in this regard.
Thanking you.
Yours faithfully,
(CS Dhananjay Shukla)
President
The Institute of Company Secretaries of India
To*
Dr. Amith Kumar
Deputy Director
Ministry of Corporate Affairs
*Subject:* Request for Extension of MCA Filing Deadlines
*Respected Sir,*
On behalf of several companies and professionals, we respectfully submit this representation seeking an extension of the MCA filing deadlines. Many stakeholders are facing significant challenges in completing their statutory filings due to the following issues:
1. *DSC association problems* – Digital Signature Certificates are not getting properly associated, causing delays in filing.
2. *Form download issues* – At times, only attachments are downloading, while the main forms fail to download.
3. *Unsigned financials* – Financial statements remain pending as directors are unable to sign due to technical glitches.
4. *Portal difficulties* – The MCA portal is experiencing frequent errors, making it difficult to upload and submit forms on time.
5. *Compliance burden* – With multiple companies affected, there is widespread concern about meeting statutory deadlines despite best efforts.
In light of these genuine difficulties, we humbly request that the Ministry grant a *one-time extension* for filing annual returns and financial statements. This will provide relief to companies and professionals, ensuring compliance without undue hardship.
We sincerely appreciate your consideration and support in this matter.
*Yours faithfully,*
[Your Name / Organization]
—
This version is structured, respectful, and highlights the exact pain points you mentioned.
Would you like me to also *add references to the recent MCA circulars* (like the October 2025 extension notice) so the letter feels more aligned with current policy updates?
Much needed extension. lot of problems in filing forms. Not able to edit the excel files downloaded and many other issues
As on 20.12.2025, when the Institute has taken up the issue, hardly 9 (NINE)working days are remaining till the extended due date for filing the annual returns, i.e., till 31.12.2025. Their request for resolving the technical issues at the earliest or alternatively extension of time limit for filing is ridiculous. Suppose the technical issues are resolved at the earliest, say on 22nd or later, how the Institute authorities are thinking the piled up filing cases can be completed within the remaining handful of days. They should have stuck to the request for extension of time limit only; resolving the technical issues is the bounden duty of the MCA, the regulator. Further, with all these technical glitches in their system, keeping silent about the levying of hefty penalties and additional fees for the delayed filing is not at all justifiable. They should be requested to come out with necessary notification announcing relaxatioins in this regard also.