September is a crowded month for company compliance — DIR-3 KYC, the AGM itself, and the filings that follow the AGM all cluster together, and missing the order they need to happen in causes almost as much trouble as missing a date outright.
DIR-3 KYC for all directors is due 30 September every year. The AGM for most private companies must also be held by 30 September, with AOC-4 and MGT-7 due within 30 and 60 days of the AGM respectively.
Important DIR-3 KYC Update (2026): The MCA has introduced significant changes to the DIR-3 KYC framework effective from 31 March 2026. The earlier annual DIR-3 KYC filing requirement has been replaced with a new compliance cycle under which most DIN holders are required to complete KYC once every three financial years, subject to the applicable transitional provisions. The due date framework has also shifted from the traditional 30 September timeline to a revised compliance schedule. However, directors must continue to update changes in their email address, mobile number, residential address, or other prescribed particulars within the specified time limits. Since the transitional rules depend on the year of DIN allotment and prior KYC compliance status, directors should verify their individual filing requirement on the MCA portal before assuming that a filing is or is not due.
Tracking multiple director KYC filings and an AGM deadline at once? WhatsApp us and we’ll map out exactly what’s due when for your company.
Quick Summary
| Filing | Due Date |
| DIR-3 KYC (all directors with a DIN) | 30 September |
| AGM | 30 September |
| ADT-1 (auditor appointment) | 15 days from AGM |
| AOC-4 (financial statements) | 30 days from AGM |
| MGT-7 / MGT-7A (annual return) | 60 days from AGM |
Why the Order Matters
DIR-3 KYC is independent of your AGM — every director with a DIN files it personally, every year, regardless of company-level events. But AOC-4 and MGT-7 are sequenced from the AGM date, not from a fixed calendar date. If your AGM happens later than 30 September for a valid reason (an extension granted by the Registrar, for instance), your AOC-4 and MGT-7 due dates shift along with it — they don’t stay anchored to a fixed date the way DIR-3 KYC does.
This is where companies sometimes get the sequence backwards: filing AOC-4 based on what they assume the deadline “should be,” rather than calculating it from when the AGM actually happened.
What Triggers a DIN Deactivation
If DIR-3 KYC isn’t filed by the due date, the DIN gets marked “Deactivated due to non-filing of DIR-3 KYC” on the MCA portal. Reactivating it requires filing the form along with a late fee, and until it’s reactivated, that director can’t be validly appointed or continue in certain filings tied to their DIN.
A Common AGM Mistake: Confusing “Held” With “Filed”
The AGM due date is about when the meeting itself takes place, not when the related forms are filed. A company can hold its AGM on time and still miss AOC-4 or MGT-7 if nobody tracks the 30-day and 60-day windows that follow. Treat the AGM date as the start of a new countdown, not the finish line.
What a Deactivated DIN Actually Blocks
A deactivated DIN isn’t just a flag on one form — it blocks that individual from being validly listed as a signing director on any MCA filing across any company they’re associated with, not just the one where the KYC lapsed. For someone who sits on the board of multiple companies, a single missed KYC deadline can quietly freeze filings across their entire portfolio of directorships until it’s reactivated. This is part of why MCA treats KYC compliance as tied to the person, not the company — the DIN belongs to the individual director, and its status follows them everywhere they’re listed.
References
- Companies Act, 2013 — Section 164 (director disqualification for continuous default)
- Companies Act, 2013 — Section 248 (company strike-off for persistent non-filing)
- MCA21 portal FAQ on DIR-3 KYC, mca.gov.in
⚠️ mca.gov.in blocks automated verification of specific page links — confirm the current FAQ/notification directly on the portal rather than relying on a third-party link.
Last Updated: 22 June 2026
Reviewed By: TaxKitab Direct Tax Team
Frequently Asked Questions
Does a newly incorporated company need to hold an AGM in its first year?
First AGMs have a slightly different timeline than subsequent years — generally within nine months of the end of the first financial year, rather than the standard September deadline. Don’t assume the standard September date applies to a company’s very first AGM.
What happens if a director’s DIN is already deactivated when DIR-3 KYC season comes around again? The KYC filing can still be done to reactivate it, along with the applicable late fee — the deactivation isn’t permanent, but it does need to be actively resolved rather than waiting for it to resolve itself.
Can a private company get an extension for its AGM? Extensions can be requested from the Registrar of Companies for genuine reasons, but this needs to be applied for before the original due date, not after it’s already passed.
Is MGT-7A different from MGT-7? MGT-7A is the simplified annual return form for small companies and OPCs (One Person Companies); MGT-7 is the standard form for other companies. Using the wrong one is a common filing error.
⚠️ Confirm your company’s specific AGM date and resulting filing deadlines at mca.gov.in — these are calculated from your actual AGM date, not assumed from the calendar.
This kind of date-cascading compliance is exactly where the MAHAGST portal and Shop Act posts we’ve covered separately also apply — multiple regulatory calendars running in parallel is the norm for most growing companies, not the exception.
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