Everything You Need to Know About Form AOC-4 on MCA Portal: A Comprehensive FAQ
Summary: The Ministry of Corporate Affairs (MCA) has launched an updated AOC-4 form on the V3 portal for the financial year ending March 31, 2025, introducing changes to enhance compliance and data accuracy. For smooth filing, the article advises using the offline mode due to the form’s complexity. A key clarification is that both the PDF of the Auditors’ Report and the Directors’ Report must still be attached in the e-filing, and content should be copy-pasted into the e-Director’s Report, summarizing only where character limits apply. It is mandatory to mention the director’s address below their name and DIN to avoid resubmission requests from the Central Processing Centre (CPC). The form requires proper, non-abbreviated signatures (no “SD/-“). The new AOC-4 is a conditional Straight Through Process (STP) form, meaning it may sometimes require manual intervention. Furthermore, the AOC-4 cannot be revised directly by the company; amendments require a complete procedure and approval from the Registrar of Companies (ROC). Non-applicable sections for small companies should be marked “Not Applicable.”
In this article, we will address frequently asked questions about the new AOC-4 form, highlighting key updates, mandatory fields, and practical tips for smooth filing. Whether you’re a corporate professional or an auditor, this guide will help you navigate the revised form with ease and confidence.
We have been receiving numerous queries from professionals and corporates across the country regarding the new AOC-4 form, particularly concerning
i. Whether we should file it Online or Offline?
ii. Whether in e-Directors Report or Auditors Report- we can mention as mentioned in PDF file or refer clause this of PDF file?
iii. Is it still mandatory to attach PDF of Auditors Report and Directors Report?
iv. As some points of Directors Report have character limit. How to fill them?
v. As some points of e-directors report not applicable on small Company. How to fill them?
vi. Whether Financials can be sign as SD/- instead of actual Signing.
vii. Whether it is mandatory to mention address of Director below their address?
viii. AOC 4 is STP form or non STP form?
ix. Whether AOC-4 can be revise?
Question 1: Whether we should file it Online or Offline?
AOC-4 on the MCA V3 portal offers both online and offline filing options. However, due to the length and complexity of the form, it is advisable to choose the offline mode. The offline mode allows you to download the form, fill it out, and upload it once completed, providing more flexibility and time to ensure all the necessary details are accurately entered.
Question 2: Whether in e-Directors Report or Auditors Report- we can mention as mentioned in PDF file or refer clause this of PDF file?
You should refer to the relevant clause or section of the Directors’ or Auditors’ report as per the contents in the PDF file. Then copy paste whole in e-Directors Report and auditors Report. The report can be mentioned in a summarized form with appropriate references in the e-form, where there is character limit. But only mentioning references can be consider as noncompliance.
Under Section 447 of the Companies Act, if it is found that the documents were intentionally misleading or fraudulent, the penalties can be more severe, including imprisonment
Question 3: Is it still mandatory to attach PDF of Auditors Report and Directors Report?
Yes, the PDF of the Auditors’ Report and Directors’ Report must still be attached in the e-filing of AOC-4. This is essential for submission as per the new MCA V3 filing process, and they are required for compliance verification.
Question 4: As some points of Directors Report have character limit. How to fill them?
If there is a character limit for certain sections in the e-Directors’ Report, you should summarize the content as briefly and clearly as possible, ensuring it captures the essential points. For detailed content that exceeds the limit, you can provide a reference to the full report in the form along with summarized matter.
Question 5: As some points of e-directors report not applicable on small Company. How to fill them?
Answer: If certain sections in the e-Directors’ Report are not applicable to a small company, these fields should be mentioned as “Not Applicable.”
Question 6: Whether Financials can be signed as SD/- instead of actual Signing?
Answer: No, the financials should not be signed as “SD/-.” The financials require a proper signature using the manual signature or Director’s DSC (Digital Signature Certificate).
Question 7: Whether it is mandatory to mention address of Director below their address?
Answer: Yes, it is mandatory to mention the address of the director along with their name and DIN in the Directors’ Report and other financial statements submitted to the ROC. Recently, there have been several cases where the Central Processing Centre (CPC) has requested resubmission of balance sheets due to the omission of the director’s address. Therefore, to ensure compliance and avoid resubmission requests, it is important to include the director’s address in all relevant documents.
Question 8: Are AOC-4 STP form or non STP form?
Answer: The AOC-4 form under the new MCA V3 system is a conditional STP (Straight Through Process) form. In some cases, it is processed automatically by the MCA without manual intervention, provided the information is correct and complete. However, in certain instances, it may not follow the STP process and require manual intervention. The MCA has not openly disclosed the specific cases where AOC-4 would be classified as non-STP, leaving these conditions unclear for corporates. Therefore, it is essential to ensure the form is accurately filled to minimize the chances of manual review.
Question 9: Whether AOC-4 can be revised?
Answer:AOC-4 cannot be revised by simply filing a new form. The revision process for AOC-4 involves a complete procedure and requires approval from the ROC. The company must submit certain documents to the ROC for the revision. It is not possible to revise the AOC-4 directly on the MCA portal by the company itself. The necessary steps and approval process must be followed to make amendments or corrections to the previously filed AOC-4.
Conclusion
The new AOC-4 form under the MCA V3 portal brings crucial updates to enhance compliance, accuracy, and ease of filing for companies. As we’ve explored in this article, it is essential for professionals to understand the intricacies of the form and ensure all fields are filled correctly to avoid delays and penalties. From choosing the right filing mode to complying with mandatory document attachments, each step plays a vital role in seamless compliance. By following the guidelines provided, you can navigate the revised AOC-4 filing with confidence, ensuring smooth submission and a hassle-free process. Stay informed, stay compliant, and ensure your company’s filings are always on time and error-free.
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Author – CS Divesh Goyal, GOYAL DIVESH & ASSOCIATES Company Secretary in Practice from Delhi and can be contacted at csdiveshgoyal@gmail.com).
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