Form DPT-3: What to Report, What to Ignore & Where Filers Get Stuck

Summary: Form DPT-3 is an annual MCA filing that reports a company’s deposits and certain outstanding loans as of 31 March each year, with the filing due by 30 June. The central principle is that only amounts outstanding on 31 March are reportable; transactions borrowed and fully repaid before that date generally do not require disclosure. The form applies to most companies, including private companies, public companies, OPCs, small companies, and Section 8 companies, while government companies are exempt. Loans from directors, inter-corporate loans, foreign loans, share application money pending beyond permitted timelines, and certain other outstanding borrowings may require reporting. Trade payables, lease liabilities, bank guarantees, letters of credit, and other non-borrowing items are generally outside its scope. The article emphasizes correct classification of shareholder loans, proper reporting of only utilized bank limits, reconciliation with financial statements, and timely filing. It also notes that while nil filing may not always be mandatory, many companies choose to file a nil return as a precautionary compliance measure.

Form DPT-3 Made Simple: what to report, what to ignore, and the questions everyone gets stuck on.

People panic about Form DPT-3, but the idea behind it is simple. Once a year, your company tells the MCA about the loans and money it still owed on 31 March — not every loan you took during the year, just whatever was still unpaid on that one date. Get that single idea, and most of the confusion disappears.

THE ONE IDEA THAT CLEARS UP MOST DOUBTS

DPT-3 looks at a single date data i.e 31 March. Doesn’t matter what the transaction is during the year. Outstanding as on 31^st March needs to report.

Borrowed and fully repaid before 31 March? Nothing to report.

For bank limits (OD/CC): only the amount actually used and still owed counts — never the sanctioned limit.

Due date: file by 30 June every year, using the 31 March position.

The basics, quickly

– What it is — a yearly return about your company’s deposits and loans, filed under Rules 16 and 16A of the Companies (Acceptance of Deposits) Rules, 2014.

– When — by 30 June every year, based on the position as on 31 March.

– Who files — almost every company. Only Government companies are out.

When you usually DON’T have to file

If nothing was owed on 31 March — no deposits and no reportable loans — filing is normally not required.

– Example: you borrow ₹25 lakh in July and repay all of it in February. On 31 March you owe nothing. No filing.

Bank limits (overdraft / cash credit) follow the same logic — only what you actually used and still owe counts:

– Limit of ₹1 crore, never used → nil owed → no filing.

– Used ₹40 lakh, still owed on 31 March → file (report ₹40 lakh).

– Used ₹50 lakh during the year but fully repaid by 31 March → no filing.

Remember: you report the amount used and still owed — the sanctioned limit itself is never reported.

What you DO report (if still owed on 31 March)

Many loans the rules don’t call “deposits” must still be mentioned if they are outstanding on 31 March. The common ones:

– Loan from a director — yes, report it. Keep the director’s written declaration that it is their own money (not borrowed from someone else), plus the board records.

– Loan from a director’s relative — for a private company this can be exempt if the relative gives the prescribed declaration; otherwise check the position carefully. Report where required.

– Loans from companies — from a holding, subsidiary, associate, or any other company. Usually exempt from being a “deposit,” but still reported if owed on 31 March.

– Loan from a shareholder — the tricky one. It often does NOT sit in the “not-a-deposit” bucket — it is treated as a deposit. If so, you choose the deposit option and attach the auditor’s certificate. Check the exemption conditions before you pick a category.

– Share application money — money received for shares not yet issued. Fine if you allot or refund within the allowed time. Miss that window and it can turn into a deposit.

– Debentures (CCDs and NCDs) — if outstanding on 31 March, examine the terms and report accordingly.

– Foreign loans (ECB) — report if outstanding on 31 March.

Things that usually stay OUT

– Supplier dues / trade payables (including MSME dues) — these are not loans, so normally not reported.

– Lease liability (Ind AS 116) — an accounting entry, not money received, so usually out.

– Bank guarantee — just a promise by the bank; nothing was received, so normally out. Only if it is invoked and becomes a loan does it come in.

– Letter of Credit (LC) — same idea; out unless it “devolves” into an actual borrowing.

– Bill discounting — Genuine trade bill discounting is out; but if it shows up as a borrowing still owed on 31 March, examine it.

– Customer security deposits / advances — normal business advances are usually out, unless they stay unadjusted beyond the allowed time or break the rules’ conditions.

Who signs the form

Any one of — a Director, the CFO, the CEO, the Company Secretary, or the Manager — with a valid digital signature (DSC). There is no separate practising-professional certification on DPT-3 itself; the only professional certification is the auditor’s, and only for deposit returns.

Should you file a NIL return anyway?

– Strictly, if there is nothing to report, you may not need to file.

– But many professionals file a NIL DPT-3 anyway, to stay safe and avoid questions later.

– Take a call on your facts — when in doubt, filing NIL is the cautious choice.

Common mistakes to avoid

– Reporting a shareholder loan in the wrong bucket.

– Reporting the sanctioned bank limit instead of the amount actually used.

– Forgetting inter-corporate / group-company loans.

– Reporting loans that were already repaid before 31 March.

– Picking the wrong filing category (leads to MCA resubmission).

– Figures that don’t match the financial statements.

– Missing share application money that has crossed its time limit.

What if you don’t file?

Late filing means extra fees — a multiplier on the normal fee that grows with the delay. And if there is a genuine deposit problem behind the non-filing, the penalties under the Companies Act are heavy, and the Registrar can ask for explanations. So, treat DPT-3 as more than a small-fee formality — the real risk sits in the classification of your loans, not in the form itself.

General guidance on Form DPT-3 under the Companies (Acceptance of Deposits) Rules, 2014; not advice on a specific filing. Treatment of individual transactions can vary on facts — review the live form’s instruction kit and your own records before filing.