A S BANKA ADVISORS

Fifty-three days. That is the runway your company has before MCA21 V2 stops accepting fresh filings on June 30, 2026 and slides into read-only mode on July 1. If you are a founder or CFO running an Indian private company, this is the cutover that changes how every charge filing, annual return, and DSC sign-off gets done starting Q2 FY 2026-27. And the conversations I am having with practitioners this week suggest most portfolios are not ready.

This is not a bureaucratic footnote. It is operational risk you can quantify in lost days and re-filing fees, especially on time-bound forms like CHG-1 charge filings, where Section 77 of the Companies Act 2013 keeps a hard 30-day clock that does not pause for portal cutovers.

Why founders should care this week, not in June

Most founders treat the V2 to V3 portal migration as a back-office detail their CA or Company Secretary handles silently. That assumption is what creates risk. The five operational gaps practitioners are hitting in Week 7 of the sprint are gaps that surface in your filings if your professional has not budgeted time for them:

1. Orphan Digital Signature Certificates (DSCs) registered only on V2. Every active director and authorized signatory needs a 10 to 15 minute OTP-plus-DSC re-association on V3. Multiply that by the number of signatories across your group entities; this is not a 30-minute job.
2. Charge filings stuck mid-workflow (CHG-1, CHG-4, CHG-9). If a lender disbursed funds in May and your CHG-1 is in “Pending payment” or “Mark for resubmission” status, the Section 77 30-day clock keeps running. A V2 cutover does not extend it.
3. Historical attachments living only on V2. Your MoA/AoA, board resolutions, AOC-4 attachments and INC-22 filings need an off-portal copy before July 1. Read-only access is not a substitute when you face a tax audit, a due diligence request, or a litigation discovery in FY 2027.
4. V2 SRN numbers in client correspondence. Every NOC, GST registration, banking letter or government communication that quotes a V2 SRN as evidence will need a V2-to-V3 cross-walk. This is a real deliverable for your finance and compliance team, not a memo.
5. Scanned PDF attachments failing V3 validation. V3 enforces under-6-MB file sizes, OCR-enabled PDFs, and stricter naming. Old scanned-only attachments that sailed through V2 will fail V3 and stall fresh filings.

What founders should demand from their CA or CS this month

The 8-week sprint we are running with our portfolio looks like this. Use it as a checklist when you have your next compliance review:

• By Friday, May 22: Every active director and authorized signatory in your company has a re-registered DSC on V3. No exceptions.
• By Friday, May 29: Every open CHG-1, CHG-4 or CHG-9 has a documented decision: complete on V2 or restart on V3. Coordinate with your lender so they do not retain a V2 SRN reference for a charge that is migrating.
• By Friday, June 5: Your CA has drafted FY 2025-26 MGT-7, MGT-7A and AOC-4 in V3 trial mode. The 60-day Section 92 clock still applies from your AGM date, but early drafting in V3 surfaces schema mismatches while V2 remains available for cross-checks.
• By Friday, June 12: A complete off-portal repository of every historical attachment exists, organized by entity, financial year, and document type.
• By close of business Friday, June 26: Every V2-only filing in your portfolio is signed and uploaded. Treat this as the real deadline. The final 96 hours before July 1 will see portal congestion, DSC validation timeouts, payment retries, and an MCA help-desk SLA stretching from 48 hours to 7 to 10 days.

The cost of waiting until late June

If a CHG-1 is not signed and uploaded by June 26 and slips into July 1, the consequence is concrete: re-filing on V3 with fresh fee, fresh DSC affixation, fresh attachments. Section 77 is not extended for portal migrations. And if your charge security is being relied on by a lender for a tranche, that delay can cascade into your treasury timeline. None of this is hypothetical.

For founders running multi-entity groups

If you operate a group with five or more entities, the migration load is non-linear. Each entity carries its own DSC re-registration list, charge filings, historical exports, and SRN cross-walk. Plan board-level visibility on the sprint, not just professional-level execution. A clean cutover at June 30 is one of those compliance details that, if missed, surfaces in due diligence as a red flag for an investor or acquirer six months later.

Download the full T-53 Days carousel

We have packaged the full 8-week sprint calendar, the 5 migration gaps, and the 9-step playbook into a 9-slide carousel for board briefings and CA reviews. Download the full carousel PDF.

Need help sequencing your cutover?

If you are running a multi-entity portfolio and the 53-day clock is starting to feel uncomfortable, talk to us. A S Banka Advisors Private Limited helps founders sequence regulatory transitions like the V2 cutover with practitioner discipline. Book a quick call.