Major Changes in ROC Annual Filing – Simplifying Forms AOC-4 and MGT-7/MGT-7A (Effective July 14, 2025)

Introduction

As part of the ongoing overhaul of corporate compliance systems, significant changes are being introduced to ROC annual filing forms—AOC-4 and MGT-7/MGT-7A. These changes, rolling out from July 14, 2025, are aimed at enhancing transparency, improving ease of use, and aligning with the MCA V3 portal’s new architecture.

Let’s break down these changes in a simplified and structured manner.

Form AOC-4: What’s New?

Form AOC-4, which deals with filing financial statements, is undergoing major functional and structural changes:

– Web-Based Filing: The form now adopts a web-based structure with offline Excel utility support.
– Linked Sub-Forms: Auditor’s report and board’s report to be filed as connected web forms.
– Integrated AOC-1 & AOC-2: These are now conditionally included within AOC-4.
– CSR Section Removed: CSR information will now go via Form CSR-2 only.
– CFS Support: AOC-4 CFS is absorbed under the main AOC-4 structure.
– Prefill Feature: Last year’s details will auto-populate for better accuracy and speed.
– XBRL Filing Enhancements: XML format with signature is now mandatory.
– Bigger Upload Limit: Overall file upload size is increased from 8 MB to 10 MB.
– Support for CIRP Companies: Those undergoing insolvency can now file easily.

MGT-7 & MGT-7A: Simplified Yet Detailed

These forms cover annual return details and are critical for corporate transparency.

– No Linked Filings: These forms are standalone for ease of filing.
– Excel-Based Shareholder List: Now requires a structured Excel format (up to 300 MB).
– Interior/Exterior Photos Mandatory: Visual proof of premises now a requirement.
– Merged MGT-8: Contents of MGT-8 are now embedded, eliminating separate upload.
– Enhanced BO Disclosure: More fields to capture Beneficial Ownership details.
– Prefilled Data + Company Info Update: Year-end name/address and prior info included.
– Not for Display: Shareholder list will be excluded from public PDFs.

Other Supporting Forms – Highlights

– ADT-1 / ADT-2 / ADT-4: More detailed, mandatory online submission for auditor appointments and resignations.
– CRA-2 / CRA-4: Available only online; CRA-4 remains in XBRL with added tagging.
– GNL-1: Now includes additional compliance-related fields like DIN/PAN, AGM due dates.
– MGT-15: Requires CS signature; shows applicable financial year.
– CSR-1: More geo-location and structural fields for transitioning companies.

What to Prepare As a Company

If you’re handling annual compliance, ensure your systems and teams are ready for:
– Collecting and converting documents into proper formats (Excel, XML, photos).
– Aligning auditor and board report formats for web-based linked filing.
– Checking CIRP or liquidation-specific fields if applicable.
– Training staff on the updated V3 portal procedures.

Final Thoughts

These changes signal a strong move toward automation, pre-validation, and structured reporting. While it may feel like an adjustment at first, these enhancements are designed to simplify long-term compliance, improve data transparency, and reduce duplication across filings.

It’s advisable to stay proactive, ensure data is organized well in advance, and get accustomed to the new filing tools before the July 14, 2025 deadline kicks in.

 

 

Summary of Key Changes

Category	Before (Old Process)	After (Effective July 14, 2025)
Form Format	PDF format upload with static fields	Web-based form + Excel utility + linked filings
AOC-1 & AOC-2	Filed separately	Auto-integrated as part of AOC-4 if applicable
Board & Auditor Reports	Uploaded as attachments	Filed through separate linked web forms
CSR Reporting	Included in AOC-4	Removed; to be filed separately through CSR-2
XBRL Filing	Standard XBRL with physical signature	Requires signed XML financial statements
CFS (Consolidated FS)	Filed separately using AOC-4 CFS	Integrated within AOC-4
CIRP / Liquidation Firms	Limited support	Now enabled for AOC-4 & MGT-7/7A
Prefill Option	Manual entry every year	Prior-year data prefilled with editable fields
Attachment Size Limit	8 MB total	Increased to 10 MB total
Shareholders List (MGT-7)	Free-text or scanned PDF	Structured Excel (up to 300MB in total attachments)
Photographs (MGT-7)	Not required	Mandatory interior and exterior office photos
MGT-8	Separate attachment	Merged within MGT-7/MGT-7A
ADT Forms (Auditor)	Partially online	Fully online with more granular fields
CRA & GNL Forms	Mixed modes	Mostly online with updated field-level validations