Short answer: AOC-4 within 30 days of the AGM, MGT-7 within 60 days. Both clocks start on the date the AGM was actually held. The additional fee is ₹100 per day per form with no cap — and a late filing can cost a private company its exemption from the internal financial controls audit, which is usually the larger number.
Most companies treat these as a December problem. They are not. Both periods run from your AGM, so holding the meeting early moves the deadlines forward with it.
The two filings
| AOC-4 | MGT-7 | |
|---|---|---|
| What it files | Financial statements | Annual return |
| Section | 137 | 92 |
| Due within | 30 days of the AGM | 60 days of the AGM |
| Small company / OPC | Same form | MGT-7A |
They are independent. Filing AOC-4 on time does not protect you on MGT-7, and the additional fee runs separately on each.
The clock starts at the AGM, not on a date
Two companies, same financial year:
- Company A holds its AGM on 12 August. AOC-4 is due 11 September; MGT-7 is due 11 October.
- Company B holds its AGM on 30 September. AOC-4 is due 30 October; MGT-7 is due 29 November.
Same year, deadlines seven weeks apart. An early AGM does not buy time — it spends it. Companies that hold the meeting early and then work to the "usual" dates are the ones that default without realising.
And where no AGM was held, the period runs from the date it ought to have been held. Skipping the meeting does not stop the clock; it just removes the event that would have reminded anyone.
What a late filing actually costs
The ₹100 per day, per form additional fee is the visible cost, and it is uncapped. Two years of inattention on both forms is not a rounding error.
The costs that never appear on the challan matter more:
The IFC exemption. A private company sitting comfortably inside every financial threshold still loses the Section 143(3)(i) exemption if it has defaulted under Section 137 or Section 92. The consequence is a full internal financial controls audit — documented processes, a risk and control matrix, walkthroughs, sample testing across the year, and IT general controls around the accounting system. Against that, ₹100 a day is trivial. The whole test, with a self-check, is in is IFC applicable to your private company.
Director disqualification. Section 164(2) disqualifies a director where the company has failed to file financial statements or annual returns for three continuous financial years. The disqualification runs five years and attaches to the individual — it follows them into every other company where they hold office. Section 167(1) then operates on the office itself.
That first consequence is the argument worth making to anyone weighing whether a late filing "really matters". The fee is small; the audit it triggers is not.