Which annual return applies, MGT-7 or MGT-7A?
How Form MGT-7 and Form MGT-7A differ, who files which, the 60 day window that runs from the AGM, and how the current small-company limits decide the form.
In this guide
A One Person Company and a small company file the annual return in Form MGT-7A; every other company, including every public company, files Form MGT-7. Both are the section 92 annual return and both are due within 60 days of the AGM, or of the date the AGM should have been held. Small-company limits are Rs 10 crore paid-up capital and Rs 100 crore turnover.
What is the section 92 annual return?
The section 92 annual return is the snapshot a company gives the Registrar of its own particulars as at the close of the financial year: registered office, share capital, members, directors, and the other matters section 92 lists. It is not the financial statements. Those go up separately in AOC-4.
Two e-forms carry that snapshot. MGT-7 is the full return. MGT-7A is the shorter return that a One Person Company or a small company files. The duty to file is the same. Only the form changes.
Who files MGT-7A instead of MGT-7?
A One Person Company and a small company file MGT-7A; every other company files MGT-7. Rule 11 of the Companies (Management and Administration) Rules 2014 makes that split, and it has applied from the financial year 2020-21. A public company cannot be a small company, so it files MGT-7 even if its capital and turnover look modest.
| Company | Form |
|---|---|
| One Person Company | MGT-7A |
| Private company that meets the small-company test | MGT-7A |
| Any other company, including every public company | MGT-7 |
A company that grew past Rs 10 crore paid-up capital or Rs 100 crore turnover during the year files MGT-7 for that year. Status is tested against the definition, not against the form used last time.
Can a private subsidiary use MGT-7A?
No. A holding company and a subsidiary company are excluded from the small company definition in section 2(85) whatever their capital and turnover, so a private subsidiary files MGT-7. Section 8 companies and companies governed by a special Act are excluded on the same footing.
When is the MGT-7 60-day window?
The MGT-7 window is 60 days from the date of the annual general meeting under section 92(4) of the Companies Act 2013, so an AGM on 25 September makes the annual return due by 24 November. If the meeting is not held, the same 60 days run from the last date on which it should have been held, and the filing has to give the reason. Two companies with different AGM dates therefore have different deadlines for the same financial year.
That is why a printed "30 November" date only works for a company that held its AGM on the last permitted day. Count from the actual meeting. MCA sometimes relaxes the additional fee by circular when the portal is under strain. Treat any such relief as a notification you open, not as a standing extra month.
What does a late annual return cost?
A late MGT-7 or MGT-7A costs Rs 100 per day of delay as an additional fee under section 403 of the Companies Act 2013, with no upper cap. That is charged separately from the AOC-4 additional fee, so a company late on both pays Rs 200 per day across the two filings. Dates for the whole pack sit in MCA annual filing due dates.
What are the small-company limits now?
A small company is one whose paid-up capital does not exceed Rs 10 crore and whose turnover does not exceed Rs 100 crore, and which is not a public company. Section 2(85) of the Companies Act 2013 carries the definition and rule 2(1)(t) of the Companies (Specification of Definition Details) Rules 2014 carries those two figures, which MCA has revised more than once.
G.S.R. 880(E) dated 1 December 2025 substituted that clause so the paid-up capital shall not exceed ten crore rupees and the turnover shall not exceed one hundred crore rupees. Open the current notification before you rely on an older four-crore / forty-crore note. Holding, subsidiary, and section 8 companies stay outside the definition even when the numbers fit.
When is Form MGT-8 required?
Form MGT-8 is required where the company is listed, or where its paid-up capital or turnover crosses the thresholds stated in section 92(2) of the Companies Act 2013, in which case a practising company secretary certifies the annual return. The certificate attaches to MGT-7 and is never part of MGT-7A.
Mixing the two is a common portal rejection: attaching MGT-8 to a 7A filing, or filing MGT-7 without the certificate when 92(2) applies. Read the current form instructions for the capital and turnover triggers before you skip the certificate.
How do I confirm which MGT form applies?
Confirm the form from section 2(85) and the current specification-of- definition rules, then check the live MGT-7 and MGT-7A versions on the MCA e-filing pages. Five steps close the loop.
- Read section 92 for the 60 day window and the MGT-8 trigger.
- Check section 2(85) and the latest amendment of the specification-of-definition rules for the small-company rupee figures.
- Open the MCA e-filing pages for the live MGT-7 / MGT-7A version and fee.
- Look for any MCA circular that relaxes additional fee for the year you are filing.
- Save the source notification with the filing records.
Why is the wrong MGT form filed?
The wrong MGT form is usually filed because last year's choice is repeated without re-testing the company against section 2(85) for the year being reported. These are the recurring failures.
- Filing MGT-7A after the company has crossed Rs 10 crore paid-up capital or Rs 100 crore turnover.
- Counting 60 days from 31 March instead of from the AGM.
- Treating a public company as small because its turnover is low.
- Skipping MGT-8 on an MGT-7 filing that section 92(2) covers.
- Using last year's small-company figures after a definition notification has moved them.
Where are small-company limits revised?
Small-company limits are revised by MCA notification amending rule 2(1)(t) of the Companies (Specification of Definition Details) Rules 2014, and form versions and fee relaxations arrive the same way. Complied AI keeps MCA updatesin one feed so you can open the source notification behind a change instead of relying on last year's filing note. When you need the rule itself, open section 92 next to the update.
Practical checks
Common questions
What is the difference between MGT-7 and MGT-7A?
MGT-7 is the full annual return under section 92 of the Companies Act 2013, filed by every company other than a One Person Company and a small company; MGT-7A is the shorter return those two categories file. The due date is identical, 60 days from the AGM or from the date the AGM should have been held, so only the form and its length differ.
When is MGT-7 or MGT-7A due?
MGT-7 and MGT-7A are due within 60 days of the annual general meeting under section 92(4) of the Companies Act 2013. Where the meeting is not held, the same 60 days run from the last date on which it should have been held, and the filing must state why it did not take place. The date is company-specific, not a national calendar day.
Who can file MGT-7A?
A One Person Company can file MGT-7A, and so can a private company that meets the small-company test in section 2(85) read with rule 2(1)(t) of the Companies (Specification of Definition Details) Rules 2014: paid-up capital not above Rs 10 crore and turnover not above Rs 100 crore. A public company can never be a small company.
Does every company need MGT-8 with the annual return?
No. Form MGT-8, a practising company secretary's certificate, is required under section 92(2) of the Companies Act 2013 only for a listed company and for a company whose paid-up capital or turnover crosses the thresholds stated in that sub-section. A One Person Company or small company filing MGT-7A does not attach MGT-8 at all.
Our turnover crossed Rs 100 crore this year. Which form do we file?
File MGT-7, not MGT-7A. Once turnover exceeds Rs 100 crore the company fails the small-company test in section 2(85) read with rule 2(1)(t), so the shorter return is no longer available for that financial year. Status is tested against the definition for the year being reported, not against the form filed last year.
We are a private company but also a subsidiary. Can we use MGT-7A?
No. A holding company and a subsidiary company are excluded from the small-company definition in section 2(85) regardless of paid-up capital and turnover, so a private subsidiary files MGT-7. Section 8 companies and companies governed by a special Act are excluded on the same basis, even where the Rs 10 crore and Rs 100 crore figures are met.
No AGM was held. Do we still file the annual return?
Yes. Where no AGM was held, the 60-day period under section 92(4) runs from the last date on which the meeting should have been held, and the annual return must state the reason it did not take place. Not holding the meeting removes neither the filing nor the Rs 100 per day additional fee under section 403 once the 60 days pass.
What does a late MGT-7 cost?
A late MGT-7 or MGT-7A attracts an additional fee of Rs 100 per day of delay under section 403 of the Companies Act 2013, with no upper cap on the daily accrual. That charge is separate from the AOC-4 additional fee, so a company late on both forms pays Rs 200 per day in total across the two filings.
Publication method
How this guide was prepared
This guide is published by the Complied AI research desk. Its source list and stated position were checked against the official records shown below on 25 August 2026.
Automation, including AI, may assist research, drafting and structure. It does not replace the official record or amount to an independent professional review. Read our editorial standards and corrections policy.
Verification path
Official sources used
Keep reading
Related guides
- Due dates · MCAWhen is the AGM due date under section 96?When a company other than an OPC must hold its annual general meeting, how the six-month year-end clock sits next to the fifteen-month gap, the nine-month first AGM, the three-month ROC extension, and what AOC-4 and MGT-7 then follow.
- Due dates · MCAWhen is Form INC-20A due after incorporation?What Form INC-20A records, which companies must file it under section 10A, the 180 day window from incorporation, and how to confirm the current position through MCA.
- Due dates · MCAWhen are LLP Form 11 and Form 8 due each year?What an LLP has to file each year, how Form 11 and Form 8 differ, the due dates that run from the financial year end, and how to confirm the current position through MCA.