The Institute of Company Secretaries of India (ICSI) wrote to the Ministry of Corporate Affairs (MCA) on September 29, 2025, detailing numerous persistent technical glitches and challenges hindering stakeholders’ ability to file mandatory e-Forms on the newly transitioned MCA-21 V3 portal. Issues reported include difficulty in generating OTPs for forms like DIR-3 KYC (especially for foreign nationals), incorrect prefilled data being pulled into forms, errors preventing form saving and submission (such as “Validation Error: Submission Restricted“), and DSC Verification Failed errors despite correct registration. Furthermore, the ICSI noted that approved forms (like PAS-3) are not immediately reflected in the MCA master data, password reset attempts fail with a “Something went wrong” message, and there are problems with form downloading, certificate generation, and attachment size limitations (e.g., in the shareholder list for MGT-7). Citing these challenges and the recent extension of the Tax Audit Report deadline by the CBDT, the ICSI formally requested an extension for annual filing forms (including AOC-4 series and MGT-7/7A) until December 31, 2025, and a relaxation of additional fees for all forms due between September 1 and December 31, 2025, to provide relief to professionals struggling with the system instability.
Institute of Company Secretaries of India
MCA:CL: SEPT/2025 Dated: September 29, 2025
Ms. Deepti Gaur Mukerjee
Secretary
Ministry of Corporate Affairs
Government of India
Shastri Bhawan
New Delhi — 110 001
Respected Madam,
Subject: Functioning of MCA- 21 V3 Portal — Issues and Challenges faced by stakeholders — Reg.
This has reference to the transition of the compliance operations of the Ministry of Corporate Affairs from MCA-21 V2 to MCA-21 V3 platform in an attempt to embrace digital transformation and furtherance of the agenda of the Government of India’s efforts to promote Ease of Doing Business (EODB) for the India Inc. Akin to every new initiative, issues and challenges are bound to creep in. We at the Institute of Company Secretaries of India are happy to partner with the Ministry in sharing these issues of the stakeholders as well as providing support wherever possible.
In this regard, we wish to submit that as informed by professionals certain technical glitches still persist and they are not able to file the e-Forms as required under the Companies Act, 2013. Some of these issues/concerns/ technical glitches are placed below for your kind consideration and timely resolution:
ISSUES AND CHALLENGES FACED BY PROFESSIONAL
| Form/Difficulty | Issues / Challenges |
| DIR- 3 KYC and DIR-3 Web KYC | Difficulty in generating OTPs in case of foreign nationals leading to non-compliance. The newly added IVR facility is also not function in well as er the feedback received. |
| Incorrect Prefilled Data | During the filling of form users are facing issue where details are incorrect in prefilled data.
Upon inserting SRN of approved RUN form – data of some other com an is being pre-filled or is incorrect. |
| Unable to Save and Submit | Users are unable to complete the filing process when at the last moment error occurs: “Validation Error: Submission Restricted”.
MCA System is not allowing to proceed further to save Form and affix DSC. Error occurs durin ‘Save and Submit’ |
| Master Data not updated on Approval | After processing and submission of Form PAS-3/CRF etc., even after where the Forms are approved, the same is not reflected in the MCA master data. |
| Unable to upload form after affixing DSC | Even while DSC is being correctly affixed and registered on MCA portal as well, at the time of uploading the eform after affixing the DSC following error is occurring:
“DSC Verification Failed” |
| Login Issue |
“Something went wrong. Please try again later”.
|
| Unmasking/unhiding particulars of form till it is filed and submitted: |
It is requested to mask/hide details only after filling or submission of the form. |
| Time bound Approval of Forms |
|
| Minimise use of Captcha |
|
| Option to Save data of Forms may be provided |
|
| Resubmission date to be made available | In case of forms requiring resubmission, the date of
|
| Downloading issues |
This cause delay in filing forms, due to which user is unnecessaril burdened with additional fees. |
| Certificate generation issues | Sometimes Certificates are not getting generated after approval of the forms & sometimes Certificates are generated with incorrect details. |
| Attachment size issue | In some forms, even attachments are less than 10MB, it throws error that “The total size of all attachments should not be more than 10MB”. System capacity need to be improved
Maximum size of List of shareholders is 300 MB but in companies there are numerous shareholders so the stakeholders are not able to provide the details of all shareholder due to the 300MB size issue |
| Information related issues | In some forms, stakeholders have been asked to provide additional details like in form MGT -7 for example list of shareholders with Gender bifurcation details which are not available even with RTA’s. Form is also asking for date of incor oration of Forei n Institutional Investor (FII) |
We would like to bring to your attention that the Central Board of Direct Taxes (CBDT) has also extended the deadline for submitting the Tax Audit Report from September 30, 2025, to October 31, 7075
In this regard, we would like to inform you that, as conveyed by various stakeholders, technical glitches are still persisting, which have hindered their ability to file the required forms under the Companies Act, 2013. Accordingly, we wish to submit the foiiowing points for your consideration:
1. Request for extension for the annual filling forms i.e. Form AOC-4 CFS NBFC (Ind AS), AOC-4(XBRL), AOC-4, AOC-4(CFS), AOC-4 NBFC (Ind AS), MGT-7, MGT-7A till 31.12.2025 without levying the additional fee.
2. Request for relaxation in levy of additional fee in respect of forms which are due between September 1, 2025 to December 31, 2025 in light of the continuing technical challenges.
We request you to kindly consider the aforesaid practical difficulties and provide for their early resolution.
We shall be pleased to provide any further information or clarification in this regard on hearing from your good self.
Thanking You,
Yours faithfully
(CS Dhananjay Shukla)
President
The Institute of Company Secretaries of India
