Table of Contents
Table of Contents
When Should A Startup File Its First Roc Return ?
The first compliance questions new founders ask after a company is set up is how to file its ROC Return.
Pankaj Verma
When Should a Startup File Its First ROC Return ?
The first compliance questions new founders ask after a company is set up is how to file its ROC Return. The ROC filings are required under the Companies Act 2013 & missing the filing window can bring heavy penalties notices & long term compliance trouble.
Today, In this Article we will Look at When Should a Startup File Its First ROC Return on filesure.
Understanding the First ROC Return for Startups
The newly set up company mainly a private limited startup must file the first set of ROC returns within set deadlines
The filings are needed even if the startup has zero work.
The company may have started business activity, generated revenue, hired workers or received investment.
The annual return filing for private limited companies still applies.
ROC Filing Timeline for Newly Incorporated Startups
The ROC filing timeline depends on the startup year of set up & financial year closing. The financial year in India always ends on 31 March even if the company is set up mid year.
Compliance Form | Purpose | First Filing Due Date for Startups |
Form AOC-4 | Filing of financial statements | Within 180 days from Financial Year end |
Form MGT-7A | Filing of annual return | Within 60 days from AGM date |
Form ADT-1 | Appointment of first auditor | Within 15 days of AGM |
DIR-3 KYC | KYC for directors | Every year by 30 September |
INC-20A | Declaration of start of business | Within 180 days of set up |
These filings form part of needed ROC compliance for new companies.
When Should a Startup File Its First ROC Return?
The simple guide below explains filing based on month of set up:
1. Startup Incorporated Between January–March
The company set up between 1 January & 31 March gets the first financial year extended till 31 March of next year. These startups get a longer first financial year which gives more time for the first ROC filing.
Example:
The company set up a date 10 February 2024.
The first financial year ends on 31 March 2025.
The first ROC returns are filed in 2025.
2. Startup Incorporated Between April–December
The companies set up from 1 April to 31 December close the first financial year on 31 March of the same year.
Example:
The company is set up on 15 July 2024.
The first financial year ends on 31 March 2025.
The ROC returns are filed in 2025.
What are the Mandatory Filings After Company Registration?
The startups must file some forms after setting up to stay compliant with MCA annual compliance.The filings are needed even before the first ROC return.
Requirement | Form | Deadline |
Verification of registered office | INC-22 | Within 30 days |
Declaration of start of business | INC-20A | Within 180 days |
First auditor appointment | ADT-1 | Within 30 days of set up |
Maintenance of required registers | — | Ongoing |
Board meeting compliance | — | Within 30 days |
The completion of these helps smooth company set up compliance.
What are the ROC Return Documents Required for First Filing?
The list below shows the simple ROC return documents required:
Document | Purpose |
Financial statements | AOC-4 filing |
Digital signatures | Form upload |
Auditor report | Needed attachment |
Board resolutions | Approval documents |
Shareholder details | MGT-7A filing |
Bank statement | Verification |
These are part of the standard startup compliance checklist.
What are the Penalties for Late ROC Filing ?
The startups often miss ROC deadlines & the penalties are very high:
Delay Period | Penalty |
Up to 30 days | 2× normal fees |
30–60 days | 4× normal fees |
60–90 days | 6× normal fees |
90–180 days | 10× normal fees |
Beyond 180 days | 12× normal fees |
These delays may also bring issues like company marked as defaulting disqualification of directors & heavy compliance load. The understanding of MCA filing deadlines is important.
Why ROC Compliance for New Companies Is Crucial for Startups ?
The regular compliance helps startups build trust for investors.
The follow up keeps records clear & avoids penalties.
The updated legal records help with funding & banking.
The delay in mandatory filings after company registration can cause trouble in future checks.
Startup ROC Filing Due Dates
Filing Type | Form Name | Timeline |
Financial statement filing | AOC-4 | 180 days from financial year end |
Annual return filing | MGT-7A | 60 days after AGM |
Auditor appointment | ADT-1 | 15 days from AGM |
Director KYC | DIR-3 KYC | Every year by 30 Sept |
Conclusion
At last, we can conclude that for a startup it is important to file its First ROC Return. The startup must file the first ROC return after the end of the first financial year with set deadlines for AOC-4 & MGT-7A based on AGM & financial year closing.
The clear understanding of startup ROC filing due dates required documents & penalties helps founders stay compliant, avoid fines & keep the company legally safe. The focus on ROC compliance for new companies helps build trust, maintain transparency & keep the startup secure.
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