ROC Annual Filing: Key Updates on Forms AOC-4, MGT-7, and More

The Ministry of Corporate Affairs (MCA) is set to introduce a comprehensive set of 38 Company Forms effective from July 14, 2025. Below are the significant changes pertaining to Forms AOC-4, MGT-7/7A, ADT-1, and other relevant forms:

Form AOC-4 Updates

• Introduction of a new web form for the extract of the auditor’s report and the board’s report.
• AOC-1 and AOC-2 forms will be incorporated as new web forms within AOC-4.
• An offline mode has been introduced for AOC-4 alongside the regular online mode.
• The auditor and board’s report will now require linked filings for AOC-4 submissions.
• The Corporate Social Responsibility (CSR) section has been removed from AOC-4.
• There will no longer be separate forms for Consolidated Financial Statements (CFS); they will now be linked directly to AOC-4.
• AOC-4 is now accessible for companies undergoing Corporate Insolvency Resolution Process (CIRP) or in liquidation scenarios.
• Previous year’s data will be autopopulated but remains editable in AOC-4, with a requirement to state reasons for any changes.
• An offline functionality allows for data entry via Excel, which can then be uploaded.
• Corporate Financial Statements in Version 3 of AOC-4 can be filed independently, even if AOC-4 is filed under Version 2.
• If filing AOC-4 CFS separately, the Audit Report (AR) and Director’s Report (DR) must be linked.
• AOC-1 will be accessible only when an associate or subsidiary is declared.
• AOC-2 will be available solely when Related Party Transactions are recorded.
• CSR-2 will not support an independent offline mode and is limited to online submissions.
• AOC-4 for Non-Banking Financial Companies (NBFC) aligns with standard AOC-4 processes.
• AOC-4 XBRL will require signed financial statements accompanied by XML files.
• Current XBRL taxonomies will be retained.

Form MGT-7/ MGT-7A Modifications

• No more linked filings are required in MGT-7 and MGT-7A.
• Shareholder and debenture holder lists will now be managed in Excel format.
• Data concerning board, shareholder, and committee meetings will also be submitted via Excel.
• A designated table for beneficial ownership provisions has been added.
• Company name and address on the year’s end date will now be included.
• Interior and exterior photographs of the company must be submitted alongside MGT-7 and MGT-7A.
• The MGT-8 attachment has been removed and integrated directly into the form.
• MGT-7 and MGT-7A are enabled for firms under CIRP or liquidation.
• The maximum attachment size for the shareholders list in MGT-7 has been increased to 300 MB (limited to 15 files of 20 MB each), while MGT-7A remains unaffected.
• Generated PDFs for MGT-7 and MGT-7A will not display the shareholders list, similar to the format in PAS-3.

Overall File Size Adjustments

The file size limits for AOC-4, AOC-4 CFS, AOC-4 XBRL, and related NBFC forms have been increased from 2 MB to a cumulative total of 10 MB, compared to the previous limit of 8 MB.

Auditor Related Forms Changes

• ADT-1 will be available exclusively in online mode, eliminating offline submission options.
• New fields for firm registration numbers (for firms) and membership numbers (for auditors signing the balance sheet) will be included in ADT-1.
• Audit committee recommendations have been added to ADT-1 submissions.
• Similar fields for auditor registration and membership numbers have been introduced in ADT-2.
• A new form ADT-4 has been added, which will also be available only in online mode.

Updates on Other Forms

• CRA-2 will switch to an online-only submission format.
• New fields regarding the nature of appointment have been integrated into CRA-2.
• Sections addressing demergers and mergers are now part of CRA-2.
• CRA-4 is now an XBRL form, with new fields added for GNL-1 SRN.
• CRL-1 shifts to an online format as well.
• The FO service for subsidiary details in CRL-1 has been removed; this info will now be directly included in the form.
• A new field indicating the financial year for which the AGM pertains is included in MGT-15, which must now also be signed by the Company Secretary (CS).
• MGT-15 will support companies undergoing CIRP or liquidation, similar to annual filing forms.
• GNL-1 remains a non-STP form, with new fields added for DIN or PAN within the applicant details section.
• GNL-1 now includes periods of default relevant for compounding offenses.
• The due date for AGMs and the extension request dates for AGM compounding are now part of GNL-1.
• CSR-1 has undergone aesthetic changes, making the form more user-friendly.
• New area and locality fields have been integrated into CSR-1.
• A section for classification from a regular company to a Sec. 8 company is included in Part 1 of CSR-1.
• There are no significant changes to INC-22A.
• The Complaint Form (including ICP and SCP) has merged into a single non-STP form.