Thirty Days, and Then It Costs Rs 100 a Day Forever
AOC-4 is how a company files its financial statements with the Registrar, under Section 137. It is due within 30 days of the annual general meeting. Miss it and an additional fee of Rs 100 per day per form runs, and sources report that it carries no upper cap. That absence of a ceiling is what turns a forgotten filing into a serious number: a company two years late on one form is carrying well over Rs 70,000 in additional fees before anyone assesses a penalty.
The due date, worked
Thirty days from the AGM, not from the year end.
An AGM held on 30 September produces an AOC-4 due date of 30 October. An AGM held on 15 August produces 14 September.
The date follows the meeting. Companies that hold the AGM at the last permitted moment compress everything that follows.
Which variant
Form | Used by |
AOC-4 | Most companies |
AOC-4 CFS | Companies filing consolidated financial statements |
AOC-4 XBRL | Companies required to file in XBRL format |
Confirm which applies to your company, because the preparation effort differs substantially, particularly for XBRL.
What goes with it
Audited financial statements: balance sheet, profit and loss account, cash flow statement where applicable, and notes
The auditor’s report
The board’s report, with its annexures
Where applicable, the secretarial audit report, the CSR report and the statement on subsidiaries
Details of related party contracts and arrangements
Directors’ declarations as required
The board’s report is where most of the preparation time goes, because it carries disclosures that have to be assembled rather than extracted.
The sequence it sits in
Finalise the accounts
Statutory audit completed, auditor’s report signed
Board approves the financial statements and the board’s report
AGM held, accounts adopted
AOC-4 within 30 days of the AGM
MGT-7 or MGT-7A within 60 days of the AGM
AOC-4 cannot precede the AGM, because the accounts must be adopted first.
Fees
The ordinary filing fee is computed on slabs linked to authorised share capital, and the portal calculates it at filing.
The additional fee for late filing is Rs 100 per day per form, reported as uncapped.
Published fee figures for the ordinary filing vary across sources, as established earlier in this cluster. Take the number from the portal.
What happens if you never file
Beyond the accumulating additional fee:
The company cannot be struck off while filings are outstanding. The Registrar treats pending returns as a bar to processing a strike-off application, so the exit route is closed until you file.
Directors face disqualification risk where a company has not filed for the prescribed consecutive periods.
The Registrar may initiate suo motu strike-off under Section 248(1) where returns have not been filed for two consecutive financial years, which removes the company without the clean closing position a voluntary application gives.
That combination is why defaulting companies find the problem compounds: the fee grows, the exit is blocked until it is paid, and the Registrar may act first.
How Northrop LLP helps
Northrop LLP prepares the board’s report and annexures, files AOC-4 and the annual return within their deadlines, and clears backlogs where filings are overdue.