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Microlesson · 5-min read

Annual Return

# Annual Return [Section 92 & 94]

## Form of Annual Return

Type of CompanyFormSigning
OPC and Small CompanyMGT-7A (abridged)CS, or director (if no CS)
Other CompaniesMGT-7Director AND CS (if no CS → CS in practice)
Private company (startup, no default u/s 92 & 137)MGT-7CS, or director (if no CS)

## Contents of Annual Return (As at Close of FY)

  • Registered office, principal business activities, particulars of holding/subsidiary/associate companies.
  • Shares, debentures and other securities; shareholding pattern.
  • Shares held by/on behalf of Foreign Institutional Investors.
  • Members, debenture-holders, promoters, directors & KMP (with changes since last FY).
  • Meetings of members, BOD, committees (with attendance details).
  • Remuneration of directors & KMP.
  • Penalty/punishment imposed on company, directors or officers; compounding of offences; appeals.
  • Matters of certification of compliances and prescribed disclosures.
  • Other prescribed matters.

## Certification of Annual Return (Form MGT-8)

Required for:

  • Listed Company, OR
  • Any company with paid-up share capital ≥ ₹10 crores, OR
  • Turnover ≥ ₹50 crores.

Certification by a CS in practice confirms facts are disclosed correctly and adequately and the company has complied with all provisions.

Penalty on defaulting CS in practice: ₹2 lakhs.

## Filing with ROC

Copy of annual return shall be filed with ROC within 60 days of:

  • Date of AGM, OR
  • If AGM not held → 60 days from the date by which AGM should have been held (with reasons for not holding AGM).

### Penalty for Non-Filing

Company & officer in default: ₹10,000 + ₹100/day; subject to maximum:

  • Company: ₹2 lakhs
  • Officer in default: ₹50,000

## Place of Keeping & Preservation [Section 94]

  • Annual return kept at registered office, OR at any other place in India where >1/10th members reside (if SR passed).
  • Company shall place annual return on its website; web-link disclosed in BOD report.
  • Preserved for 8 years from filing with ROC.

## Inspection, Extract and Copies

  • Open for inspection during business hours (≥2 hours/day on working day).
  • Free for member/debenture-holder/security-holder/beneficial owner.
  • Any other person: fee per AOA, ≤ ₹50 per inspection.
  • Extracts free; copies ≤ ₹10 per page (within 7 days of deposit).

### Penalty for Refusal

Company & officer in default: ₹1,000/day per default, max ₹1 lakh.

Worked example

### Example 1

Example 1: A One Person Company is preparing its annual return. Which form should it use and who must sign?

Answer: OPC must file in Form MGT-7A (abridged form). It may be signed by the Company Secretary, or by a director if there is no CS.

### Example 2

Example 2: XYZ Ltd is a listed company with paid-up capital of ₹2 crores and turnover of ₹40 crores. Is MGT-8 certification required?

Answer: Yes — being a listed company, MGT-8 certification by a CS in practice is mandatory, irrespective of paid-up capital or turnover thresholds.

### Example 3

Example 3: ABC Ltd held its AGM on 30th September 2025. By when must it file annual return with ROC?

Answer: Within 60 days, i.e., by 29th November 2025. If not filed, penalty of ₹10,000 + ₹100/day starts running (max ₹2 lakhs).

⚠️ Common exam mistakes

  • Forgetting that MGT-7A is for OPC AND Small Company (not just OPC).
  • Missing that MGT-8 certification triggers on ANY ONE of: listed status, paid-up capital ≥ ₹10 cr, OR turnover ≥ ₹50 cr.
  • Calculating 60-day filing from the financial year-end instead of AGM date.
  • Forgetting to place annual return on company website and link it in BOD report.
  • Confusing the 8-year preservation period (annual returns) with permanent preservation (Register of Members).
Bare-Act text Section 92 & 94 · Companies Act, 2013 · click to expand
Every company shall prepare a return (hereinafter referred to as the annual return) in the prescribed form containing the particulars as they stood on the close of the financial year, and a copy of the annual return shall be filed with the Registrar within sixty days from the date on which the annual general meeting is held.
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