The Institute of Company Secretaries of India (ICSI) has raised serious concerns before the Ministry of Corporate Affairs (MCA) regarding the continued technical issues and challenges being faced by professionals on the MCA-21 V3 portal.
In a detailed representation addressed to Ms. Deepti Gaur Mukerjee, Secretary, MCA, the Institute highlighted a series of persistent glitches that are hampering compliance filings and requested immediate remedial action, including deadline extensions and fee relaxation.
In its communication, ICSI emphasized that the transition from MCA-21 V2 to the V3 platform—aimed at enhancing digital transformation and promoting ease of doing business—has been accompanied by a range of operational hurdles. Despite multiple feedbacks from stakeholders, many technical issues continue to persist, affecting the ability of professionals to file statutory e-forms under the Companies Act, 2013.
The ICSI submission details several technical difficulties being encountered by professionals across various forms and filing processes. Some of the major issues include:
1. DIR-3 KYC and DIR-3 Web KYC Problems
Professionals are facing difficulties in generating OTPs, especially for foreign nationals, leading to non-compliance. The newly added IVR facility is also reportedly not functioning as expected.
2. Incorrect Prefilled Data
Users have reported that during form filling, prefilled data often appears incorrect. In some cases, when SRN of approved RUN forms is inserted, data of other companies gets auto-filled erroneously.
3. Inability to Save and Submit
Frequent system errors such as “Validation Error: Submission Restricted” prevent users from completing filings. The MCA system also restricts saving and submission after affixing DSCs due to technical errors.
4. Master Data Not Updated
Even after the successful approval of certain forms such as PAS-3 and CRF, the data is not reflecting in the MCA master database, creating discrepancies in company records.
5. Certificate Generation Issues
ICSI noted instances where certificates are either not generated post approval or are generated with incorrect details, causing additional compliance complications.
6. Attachment Size and Upload Errors
The system throws errors even when attachments are under 10 MB, contrary to the prescribed limit. Moreover, for large shareholder companies, the 300 MB limit for uploading the list of shareholders is proving insufficient.
7. Information-Related Challenges
Stakeholders have been asked to provide additional data, such as gender bifurcation of shareholders in Form MGT-7—information that is not even available with Registrar and Transfer Agents (RTAs). Some forms also seek details like the incorporation date of Foreign Institutional Investors (FIIs), which are often not readily accessible.
ICSI’s Requests to the Ministry
In light of these unresolved technical glitches, ICSI has made two key representations to the MCA:
- Extension of Filing Deadlines
The Institute has requested that the annual filing due dates for forms such as AOC-4 CFS NBFC (Ind AS), AOC-4 (XBRL), AOC-4 (CFS), AOC-4 NBFC (Ind AS), MGT-7, and MGT-7A be extended till December 31, 2025, without the levy of any additional fees.
- Relaxation of Additional Fees
ICSI has urged the Ministry to waive off additional filing fees for forms due between September 1, 2025, and December 31, 2025, considering the ongoing technical issues that are beyond the control of professionals and companies.
Reference to CBDT’s Extended Deadline
In its letter, ICSI also cited the Central Board of Direct Taxes (CBDT)’s recent decision to extend the due date for submitting Tax Audit Reports from September 30, 2025, to October 31, 2025, as an example of regulatory flexibility in light of practical challenges.
ICSI’s Assurance of Support
ICSI reaffirmed its commitment to partner with the Ministry in resolving these technical difficulties and sharing stakeholder feedback to ensure smoother compliance operations under the MCA-21 system.
The letter, signed by CS Dhananjay Shukla, President of ICSI, concluded by urging the Ministry to consider the “practical difficulties faced by stakeholders” and to facilitate early resolution.
Background: MCA-21 V3 Rollout
The MCA-21 V3 platform was launched as part of the Government of India’s broader push for digital governance and the “Ease of Doing Business” initiative. However, since its rollout, professionals and corporates have reported recurring issues in the portal’s usability, particularly relating to prefilled data accuracy, form submission failures, and system downtime.
While the platform aims to modernize corporate compliance, the ongoing glitches have led to widespread delays and frustration among stakeholders.
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