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MCA V2 to V3 Form Transition: Key Changes & Filing Improvements

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The Ministry of Corporate Affairs (MCA) has transitioned various forms from V2 to V3, introducing significant enhancements to streamline corporate filings. Key amendments include the auto-prefill of previous year’s data in forms like AOC-4, with conditional STP (Straight Through Processing) for most. Many previously attached documents, such as the Board Report and Auditor’s Report, are now web-based linked forms, requiring specific disclosures like those related to the Sexual Harassment Act and Maternity Benefit Act.

The updated forms, including MGT-7/7A, now support revisions, require a photograph of the registered office, and mandate shareholder lists with gender and category bifurcation. Forms like AOC-1 and AOC-2 have become mandatory linked web-based forms, requiring professional certification or SRN quotation where applicable. Financial figures in new annual filing forms must be in absolute rupees. Enhanced checks for DIN/PAN validation, auditor appointment caps, and the capture of GNL-1 SRNs for AGM extensions are also integrated. The transition aims to improve data accuracy, efficiency, and compliance for corporate entities.

S. No. Form Topic V2 Format V3 Format / Key Enhancements Processing Type Filing Mode
1 AOC-4 Filing of Financial Statement AGM extension date mentioned manually. Director only could sign. No auto-prefill of previous year data. CSR, AOC-1, AOC-2, Board Report, Auditor’s Report attached as PDFs. Auto-prefill previous year data (editable with reason); SBN & MSME dues disclosure; IRP/RP/ Liquidator can sign; CSR moved to CSR-2; Board/Auditor reports filed as linked forms; Secretarial Audit table added; GNL-1 SRN captured; Security deposits fields removed; Equity/Preference bifurcation required if raised; Cost records compliance disclosures added Conditional STP (Non-STP for u/s 130/131 or capital reduction) Online / Offline
2 AOC-4 CFS Consolidated Financial Statement Filed manually with the

attachment of auditor’s report. No Secretarial Audit table. Share capital raised shown.

Linked with AOC-4; Auditor/Secretarial Audit moved to separate forms; share capital section removed; standalone & consolidated auditor extracts filed separately; offline/online supported Conditional STP (same exceptions as AOC-4) Online / Offline
3 AOC-1 Statement on Subsidiaries/JVs Attached manually with Board Report Now a web-based linked form; certification by practicing professional mandatory; file only if subsidiary/JV exists; mandatory linked if AOC-4 filed Linked Online / Offline
4 AOC-2 Disclosure of Related Party Transactions Manual attachment with Board Report Now web-based linked form; MGT-14 SRN to be quoted if applicable; CIN/ LLPIN/passport of related parties mandatory Linked Online / Offline
5 AOC-4 XBRL Filing Financials in XBRL Format Only XBRL utility, no signed statements (PDFs) Signed financials (PDF) to be attached. CSR applicability enabled. Linked CSR-2 if applicable. Form now Web-based.

STP mode with checks for capital changes

Conditional STP Web-based
6 MGT-7 / 7A Annual Return No revision option; Gender-wise shareholder info not required; photograph of office not required; MGT-8 as attachment Revised filing enabled; office photo mandatory; shareholder list in Excel with gender/ category bifurcation; MGT-8 merged into form; Rule 9(4) declaration integrated; SRN of GNL-1 & revised financials required; Latitude/ Longitude fields added; Share transfer via Excel STP Online / Offline
7 MGT-15 AGM Report Only AGM date required; any officer could sign Must include financial year; CS signature mandatory; allowed for companies under CIRP/Liquidation STP Web-based
8 GNL-1 Application to ROC Basic details filing only DIN/PAN required; AGM extension fields (original & extended dates); compounding fields added Non-STP Web-based
9 ADT-1 Auditor Appointment No CG/ NCLT option, No INC-28 SRN for Tribunal orders; merged firm/ individual field, Audit Committee mention not required Appointment by CG and C&AG option added. Audit committee recommendation must be disclosed. SRN of INC-28 if Tribunal appointed.

Max. 20-audit cap validated

Separate fields for firm & auditor.

STP Web-based
10 ADT-2 Removal of Auditor Manual form Web-based, FRN and membership number separated STP Web-based
11 ADT-3 Auditor Resignation Only resignation reason required Additional facts to be mentioned. SRN of ADT-1 required.

Separate fields for firm and auditor

STP Web-based
12 ADT-4 Reporting to CG Manual form Now web-based

New e-form introduced

Non-STP Web-based
13 CRA-2 Cost Auditor Appointment No consent or demerger info required,

No option for new product/ service

Consent checkbox;

Now includes option for new product/ service. CIN of amalgamated entity can be mentioned. Max 20 companies check for auditor. Auditor’s contact and board meeting date added.

STP Web-based
14 CRA-4 Cost Audit Report No AGM extension field -AGM extension not captured GNL-1 SRN and AGM date required. Auditor’s mobile number and board meeting date added. STP Web-based
15 CSR-1 CSR Entity Registration Section 8 company not separately mentioned – No distinct tag for Sec 8 Co. Section 8 Company option added;

Added in “type of entity”. Web-based.

STP Web-based
16 CSR-2 CSR Reporting Due date 31 March 2025 FY 23-24 due date extended to 30 June 2025; from FY 24-25, linked with AOC-4; offline and online modes. STP /Linked (V3) Web-based
17 INC-22A ACTIVE V2 based, Manual tagging Web-based. STP Web-based

Attachment Enhancements:

  • MGT-7: Shareholder/debenture list to be attached in Excel (up to 300 MB split across 15 files) Not part of PDF.
  • 2 MB per attachment limit removed for AOC-4, AOC-4 CFS, XBRL, NBFC. (Total size limit remains 10 MB)
  • All Other Forms: Standard 2 MB per attachment and 10 MB total remains unchanged

Board’s Report – New Mandates and Disclosures (as per Rule 8):

  • Must now be filed as a linked web-form extract
  • Mandatory new disclosures:
    • Sexual Harassment Act: complaints received, disposed, pending >90 days
    • Maternity Benefit Act: compliance statement
    • Political Contributions under Sec 182(3)
    • Auditor confirmation on specified notes

Key Filing Notes:

  • Linked forms must be filed together.
  • Previous year data pre-filled; changes need justification.
  • Form extract fields (Board/Auditor/CSR) replaced earlier attachments.
  • Offline Excel-based templates introduced for AOC-4, MGT-7 and others.
  • Mandatory DIN/PAN check for ROC applications.
  • Photo of registered office and gender-based shareholding added for compliance.
  • Figures in New annual filing forms to be provided in absolute figures in Rupees instead of Round off figures.

Actionable:

  • Track GNL-1 SRNs and AGM extensions (if any) carefully.
  • File linked forms (AOC-1, AOC-2, Board/Auditor Extracts) with parent forms
  • Upload clear photo of registered office showing company name
  • Coordinate across teams for timely finalisation of linked extracts.
  • Maintain updated templates, formats, and Excel files. (Use Excel templates for bulk data (MGT-7, AOC-4) )
  • Validate all DIN/PAN, related party identifier.
  • Ensure auditor/cost auditor appointments do not exceed statutory cap
  • File all required linked forms simultaneously to avoid STP failure.

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Author Info

CS Saurabh Rai
Qualification: CS
Location: Gurgaon, Haryana
Articles Published: 5

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