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Microlesson · 5-min read

Report on Annual General Meeting [Section 121 + Rule 31]

# Section 121 — Report on AGM (Listed Public Companies)

## Applicability — Narrow Scope

Only listed public companies are required to prepare a Section 121 AGM report. Private companies, unlisted public companies, OPCs, and Section 8 (if unlisted) are not covered.

## What the Report Must Confirm

It must confirm that the AGM was convened, held and conducted as per:

  • The Companies Act, 2013, AND
  • Rules made thereunder.

## Filing Requirements

ParticularDetail
FormMGT-15
Filed withRegistrar of Companies
Time limitWithin 30 days of conclusion of AGM
FeePrescribed

## Rule 31 — Manner of Preparation

(a) Report is in addition to the minutes of the general meeting (not a substitute).

(b) Signed and dated by Chairman of the meeting; if unable, by any two directors of which one shall be the Managing Director (if any) and the Company Secretary.

(c) Contents to include:

  • (i) Day, date, hour, venue
  • (ii) Confirmation of appointment of Chairman
  • (iii) Number of members attending
  • (iv) Confirmation of quorum
  • (v) Compliance with Act, Rules and Secretarial Standards (SS-2) for calling/convening/conducting
  • (vi) Business transacted + result
  • (vii) Adjournment / postponement / change of venue particulars
  • (viii) Any other relevant points

(d) Must contain a fair and correct summary of proceedings.

## Penalty for Default (Civil Penalty — not Fine)

OnInitialContinuingCap
Company₹1,00,000₹500/day₹5,00,000
Every officer in default₹25,000 (min)₹500/day₹1,00,000

> Important: This is a penalty (adjudicated), not a fine — distinguishing it from Section 99.

Worked example

### Example 1

Example 1: Listed PQR Ltd. held its AGM on 25 September 2025. By when must MGT-15 be filed? ✅ Within 30 days, i.e., by 25 October 2025.

### Example 2

Example 2: Star (Unlisted Public) Ltd. did not file any AGM report under Section 121. Is it in default? ❌ No — Section 121 applies only to listed public companies.

### Example 3

Example 3: Listed XYZ Ltd. delays filing MGT-15 by 200 days. Maximum penalty on company? Initial ₹1,00,000 + ₹500 × 200 = ₹2,00,000, well within the ₹5,00,000 cap.

⚠️ Common exam mistakes

  • Applying Section 121 to all companies — it is listed public companies only.
  • Filing in the wrong form — the correct form is MGT-15, not MGT-7 (annual return) or MGT-14 (board resolutions).
  • Confusing the fine under Section 99 (criminal punishment for AGM default) with the penalty under Section 121 (civil penalty for non-filing of AGM report).
  • Forgetting that the report is in addition to, not in lieu of, the AGM minutes.
Bare-Act text Section 121 / Rule 31 · The Companies Act, 2013 read with Rule 31 of Companies (Management and Administration) Rules, 2014 · click to expand
Section 121(1): Every listed public company shall prepare in the prescribed manner a report on each annual general meeting including the confirmation to the effect that the meeting was convened, held and conducted as per the provisions of this Act and the rules made thereunder. (2) The company shall file with the Registrar a copy of the report referred to in sub-section (1) within thirty days of the conclusion of the annual general meeting with such fees as may be prescribed, or with such additional fees as may be prescribed. (3) Penalty as specified — company up to ₹5 lakh; officer in default up to ₹1 lakh.
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