When is Form AOC-4 due under section 137?

What is Form AOC-4?

AOC-4 is the e-form used to file a company's financial statements and related documents with the Registrar of Companies. The statutory duty sits in section 137 of the Companies Act, 2013: a copy of the financial statements, including consolidated statements where required, must go to the Registrar after they are adopted.

Almost every company that prepares financial statements under the Act will meet this filing in some form. The practical question is not whether AOC-4 exists, but which variant applies, what must be attached, and which event starts the clock for your company.

When is the AOC-4 due date?

For companies that hold an annual general meeting, the usual rule is clear: file within 30 days of the AGM at which the financial statements are adopted. If the statements are adopted in an adjourned AGM, the 30-day clock runs from that adjourned meeting.

A One Person Company does not follow the same AGM-linked path. Section 137 requires an OPC to file financial statements duly adopted by its member within 180 days from the close of the financial year, together with the documents that must attach to those statements.

The AGM itself has its own outer limit under the Act, commonly six months from the end of the financial year for a company with a 31 March year-end. That AGM limit and the AOC-4 limit are separate. Missing the AGM timing can push the whole annual pack late even if the form is ready. The AGM clocks themselves are in section 96.

What if the AGM was never held?

The AOC-4 clock still runs. Section 137(1) of the Companies Act, 2013 requires the financial statements to be filed within 30 days of the last day on which the annual general meeting should have been held, with the reasons for not holding it. A company that skipped the AGM therefore counts 30 days from its AGM deadline, not from an actual meeting date.

Does an unadopted financial statement change the date?

Yes. Where the financial statements are not adopted at the AGM or the adjourned AGM, section 137(1) lets the company file them as provisional within 30 days of that meeting, and then file the adopted statements within 30 days of the later AGM that adopts them. Two filings, each on its own 30-day count.

Which AOC-4 variant should I file?

"AOC-4" is a family of forms, not a single screen for every company. The correct variant depends on whether the company files in ordinary mode or XBRL, whether consolidated statements are needed, and whether special NBFC formats apply.

Choose the variant from the current MCA form list and instruction kit, not from last year's folder. Form versions and field requirements change by notification. If the company also has foreign subsidiaries that have not established a place of business in India, section 137 expects their accounts to travel with the Indian filing where the Act requires that attachment.

What attachments does AOC-4 need?

Rejections and resubmissions usually come from a thin attachment pack, not from the due-date math. Before you open the form, assemble:

• Signed financial statements adopted at the AGM or by the OPC member
• Board's report and the auditor's report
• Consolidated statements and notes, where the company must prepare them
• Any other document the current form instructions mark as mandatory
• Board or member approval records that support the adoption date entered in the form

The numbers in AOC-4 should match the signed PDF pack. A mismatch between the form fields and the attached statements is a common reason the filing comes back.

What is the AOC-4 late filing fee?

If AOC-4 is filed after the due date, additional fees apply under the Companies (Registration Offices and Fees) Rules. The fee escalates with delay. Beyond fees, continued default can lead to notices and further consequences for the company and officers under the Act.

MCA sometimes issues a general circular that extends a filing window or relaxes additional fees for a stated period. That relief is never automatic for every form and every year. Read the circular number, the forms named, and the period covered on the official MCA notifications page before you change a calendar entry.

How do I file AOC-4 step by step?

1. Record the financial year end and the AGM date (or OPC adoption path).
2. Confirm the correct AOC-4 variant and the current instruction kit on the MCA portal.
3. Finalise signed financial statements, board report, and auditor report.
4. Check whether consolidated statements, subsidiary accounts, or XBRL tagging apply.
5. Enter the adoption date and company particulars exactly as they appear in the signed pack.
6. Pay fees, submit the form, and save the acknowledgement and filed copy in the compliance record.
7. Diarise the related annual return (MGT-7 or MGT-7A), which generally runs on a longer post-AGM window.

Why does AOC-4 come back for resubmission?

• Planning from a fixed month instead of the company's actual AGM date
• Using last year's form variant when the company now falls under XBRL or a different CFS path
• Filing provisional or unsigned packs and expecting the ROC to treat them as final
• Mismatching figures between the e-form fields and the attached statements
• Assuming an MCA extension applies without reading the circular's form list and period
• Filing AOC-4 on time but forgetting the annual return deadline that follows

Where does MCA announce AOC-4 fee relief?

AOC-4 timing is stable in the Act, but form versions, XBRL rules, and fee-relief circulars move through MCA releases. Use MCA updates on Complied AI to open the official circular or notification behind a change, then apply it to your AGM date and form pack. For the wider annual ROC map, see the ROC filing due dates guide.