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Filing the DIR-3 KYC (Director’s KYC) is a crucial compliance requirement for directors in India, ensuring transparency and accurate information in the corporate world. However, recent issues have arisen regarding the receipt of OTP (One-Time Password) necessary for completing this filing.

The Importance of DIR-3 KYC: DIR-3 KYC is a mandatory filing for individuals who hold the Director Identification Number (DIN) as of March 31 of a financial year. The purpose is to verify and update the details of directors, enhancing the accuracy and authenticity of the information available with the Ministry of Corporate Affairs.

The OTP Challenge: Directors filing DIR-3 KYC for the financial year 2022-23 have reported difficulties in receiving the OTP required to complete the filing process. This OTP is typically sent to the mobile number registered with the Ministry of Corporate Affairs and serves as a crucial authentication step.

The Message Dilemma: Another issue arises when directors attempt to file DIR 3 Web KYC. After completing the filing process, they encounter a message stating, “This is the first-time filing; you have to file DIR 3 KYC Form.” This message creates confusion and adds an unnecessary layer of complexity to the process.

The Urgency for Resolution: With the deadline for filing DIR-3 KYC for the financial year 2022-23 set for September 30, 2023, these issues require immediate attention. Directors and professionals involved in the filing process are anxious about meeting the compliance deadline.

Conclusion: The challenges faced by directors in receiving OTP for DIR-3 KYC and the confusing message in the case of DIR 3 Web KYC are causing concerns among the corporate community. As these issues impact compliance and can lead to penalties for non-compliance, it is imperative that the Ministry of Corporate Affairs investigates and resolves these difficulties promptly. Ensuring a smooth and hassle-free filing process is essential for the efficient functioning of corporate governance in India.

*****

THE 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 Affairs)

MCA: 2023 September 27, 2023

Shri Manoj Govil, IAS
Secretary
Ministry of Corporate Affairs
Government of India
Shastri Bhawan
New Delhi – 110 001

Subject: Intimation of difficulty in receiving OTP on the mobile number of Directors while filing DIR-3 KYC

Dear Sir,

Greetings from the Institute of Company Secretaries of India !

We wish to draw your kind attention towards the provisions of Rule 12A of the Companies (Appointment and Qualification of Director) Rules, 2014. It provides that every individual who holds the Director Identification Number (DIN) as on 31′ March of a financial year shall, submit e-form DIR-3 KYC for the said financial year to the Central Government on or before 30th September of immediate next financial year.

Accordingly, the last date for filing of e-form DIR-3 KYC for the financial year 2022-23 is September 30th, 2023.

In this regard, we wish to inform you that communications are being received from the professionals that while filing DIR-3 KYC for financial year 2022-23, directors are facing difficulty in receiving the OTP on their mobile number without which Form cannot be filed.

We are also receiving communications that while filing DIR 3 Web KYC, Directors are facing difficulties because the following message is received after doing the entire exercise of filing DIR 3 Web KYC:

`This is first time filing, you have to file DIR 3 KYC Form’

It is submitted to kindly look into these matters and provide resolution as the last date i.e. 30th September, 2023 is approaching.

Thanking You

Yours Faithfully

(CS Manish Gupta).*
President

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