The Institute of Company Secretaries of India (ICSI) has urged the Ministry of Corporate Affairs (MCA) to extend the deadline for filing annual e-forms under the Companies Act, 2013, till December 31, 2026, without levying additional fees, citing persistent technical difficulties on the MCA-21 V3 portal and increased compliance requirements.
In a representation dated October 9, 2026, addressed to Dr. Pallavi Jain Govil, Secretary, Ministry of Corporate Affairs, the Institute said it had received numerous representations from stakeholders facing difficulties in completing annual filings.
The letter, signed by ICSI Secretary CS Asish Mohan, seeks a one-time extension to help companies and professionals complete accurate filings amid portal disruptions, revised forms and additional disclosure requirements.
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Portal Downtime, Login Problems and Filing Errors
According to the representation, stakeholders have reported frequent portal downtime, slow response times, session timeouts and automatic logouts during form preparation and submission.
The Institute also flagged difficulties involving login, profile updates and user access management. Errors in pre-filled information and inconsistencies in data retrieval were identified as further obstacles to completing filings.
Other concerns include problems in associating Digital Signature Certificates, form validation failures despite correct data entry, and issues relating to Service Request Number generation, payment processing and challans.
The representation also highlights difficulties in viewing, downloading and tracking filed forms and approvals. These problems, according to ICSI, affect several stages of the filing process, extending beyond the initial preparation of forms.
Revised Annual Forms Increase Preparation Time
ICSI said the migration of annual filing forms to the V3 framework has introduced significant structural and disclosure changes.
Forms such as AOC-4 and MGT-7 now require extensive information to be captured within the forms themselves, reducing reliance on attachments and increasing preparation time, the Institute stated.
Its representation links the additional time needed to prepare these revised forms with the technical difficulties reported on the portal. Together, these issues have made timely compliance more challenging for companies and the professionals handling their filings.
XBRL Filings Require Extensive Validation and Reconciliation
The Institute separately highlighted practical difficulties in preparing and filing annual financial statements and annual returns, particularly filings involving Extensible Business Reporting Language, or XBRL.
Such filings require extensive tagging, validation and reconciliation, according to the letter. ICSI said the time needed to ensure accurate reporting is further increased by portal-related challenges.
The request therefore seeks additional time to support complete and accurate compliance, particularly where detailed financial reporting must be prepared and validated before submission.
Portal Overload During Working Hours
ICSI also raised concerns about the portal’s performance during peak working hours.
According to stakeholder concerns recorded in the representation, the system frequently crashes or becomes inaccessible because of heavy concurrent traffic, especially between 11 a.m. and 6 p.m.
The Institute said these interruptions disrupt time-bound filings, adding to the difficulties faced by companies and professionals during the annual compliance period.
Forms Covered by the Request
The representation seeks relief for AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), DIR-12, ADT-1, MGT-7 and MGT-7A.
ICSI has requested that the Ministry permit the filings covered by its representation up to December 31, 2026, without additional fees.
Although the letter describes the request as concerning annual filing forms, it expressly includes DIR-12 and ADT-1 alongside the financial statement and annual return forms.
ICSI Cites Income Tax Compliance Extensions
In support of its request, ICSI referred to deadline extensions granted by the Central Board of Direct Taxes.
The letter states that CBDT Circular No. 07/2026, dated September 28, 2026, extended the income tax return filing deadline for audit cases for Assessment Year 2026–27 from October 31, 2026, to November 21, 2026. It also records that the corresponding audit report submission timeline was extended from September 30, 2026, to October 21, 2026.
ICSI cited these extensions as a precedent for recognising practical difficulties faced by stakeholders in meeting statutory compliance requirements.
One-Time Relief Sought for Companies and Professionals
The Institute said a one-time extension until December 31 would provide substantial relief while helping companies and professionals ensure accurate, complete and quality compliance.
It requested favourable consideration in the larger interest of stakeholders and in furtherance of the Government’s objectives of promoting ease of doing business and ease of compliance. The Institute also offered to furnish any additional information or clarification required by the Ministry.
The document is an ICSI request for relief; it does not itself extend any filing deadline or waive additional fees. The proposed December 31, 2026, filing window would require a separate decision or communication from the MCA.
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