Important MCA Compliance Update for FY 2024-25 Filing

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Important MCA (Ministry of Corporate Affairs) update regarding the filing of Form No. AOC-4 on the MCA V3 Portal.

The Ministry of Corporate Affairs (MCA) has announced a major revision in the filing process for Form AOC-4 (including XBRL), MGT-7, and MGT-7A applicable for financial years beginning on or after April 1, 2024. These changes, now active on the MCA V3 Portal, aim to enhance transparency, verify authenticity, and reduce shell company risks. Companies filing AOC-4 XBRL are also required to file CSR-2 (if applicable) from FY 2024-25 onwards. Here’s a summary of the key points:

For Companies Filing AOC-4 XBRL (FY 2024-25 Onwards):

Only Form CSR-2 (if applicable) is required to be filed as a linked form.
No requirement to attach the following:
- Extract of Board’s Report
- The Extract of Auditor’s Report (Standalone)
- AOC-1 / AOC-2 / AOC-4 CFS / Auditor’s Consolidated Report

Applicable only for filings via MCA V3 portal.

New Filing Requirements for AOC-4, MGT-7, and MGT-7A (Effective July 14, 2025):

Photographic Proof of Registered Office: Companies must submit three types of photos:

- Exterior View with visible building/society name
- Interior Office View showing at least one director
- Display Board Photo showing:
  - Company Name
  - CIN
  - Contact Details
  - Website (if available)

Display Board Requirements (as per Section 12, Companies Act, 2013): Information must be displayed in English and local/regional language (e.g., Hindi, Gujarati, etc.)

Director Identification: The director present in the photograph must digitally sign the forms using their valid DSC mapped in the MCA database.

Mandatory Annexures: Forms must include:

- Extracts of Board Report & Auditor’s Report
- Shareholding patterns
- MGT-7/MGT-7A linked Excel templates
- Details of meetings and resolutions (as applicable)

Mandatory Linked Forms:

All companies filing Form AOC-4 or AOC-4 NBFC (Ind AS) must now submit the following:
Extract of Board’s Report
Extract of Auditor’s Report (Standalone)

Additional Linked Forms (wherever applicable):
Form AOC-1
MCA Form AOC-2
Form CSR-2
MCA Form AOC-4 CFS / AOC-4 CFS NBFC (Ind AS)
Extract of Auditor’s Report (Consolidated)

Purpose Behind the Update:

Ensure registered office address authenticity
Prevent shell/fake company registrations
Increase director accountability
Promote transparency in ROC filings

Compliance Checklist for Companies:

✅ Prepare clear photographs of the registered office
✅ Ensure the director is present and identifiable in at least one photo
✅ Validate and map the director’s DSC on MCA
✅ Update office signage as per legal requirements
✅ Match office address with MCA records
✅ Prepare all annexures in prescribed formats (Excel/PDF)

Forms AOC-4 CFS / AOC-4 CFS NBFC (Ind AS) and Extract of Auditor’s Report (Consolidated) can only be filed independently if the original AOC-4 was filed in MCA V2.

Important Notes: No GPS metadata requirement has been officially notified. Non-compliance may lead to rejection, penalties, or delays in filings. & Start preparations early to meet filing deadlines without hassle.