A S BANKA ADVISORS

If you run a private limited company, your June 30 filing pressure just eased, but read the fine print before you relax. Following a fire at its Data Centre on June 5, 2026, the Ministry of Corporate Affairs has allowed Form DPT-3 for FY 2025-26 to be filed without additional fees up to July 31, 2026. The relief is welcome. It is also widely misread. Here is what it actually gives your company, what it does not, and the practical steps to close this out cleanly.

A fee waiver, not a new due date

MCA General Circular No. 02/2026, dated June 19, 2026, does one specific thing: it waives the additional (late) fee on DPT-3 filings made up to July 31, 2026. It does not move the statutory due date, which remains June 30, 2026 under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, read with Section 73 of the Companies Act, 2013.

For most filers the practical effect is simply an extra penalty-free month. But the legal characterisation matters, especially for directors who certify compliance. A company that files on, say, July 20, 2026 has technically filed after the statutory date, yet pays no additional fee because of the relief. File even one day after July 31 and the full additional-fee slab applies, calculated from June 30, not from July 31. Treat July 31 as a hard internal deadline, not a soft cushion.

Why the relief exists

The fire on June 5, 2026 forced an unscheduled switchover to the MCA’s Disaster Recovery site, and the capacity and restoration work that followed left several MCA21 services slow or intermittently unavailable during the peak DPT-3 window. The waiver simply ensures companies are not penalised for portal downtime outside their control. A companion measure dated June 20, 2026 also extended name reservations (RUN, RUN-LLP and SPICe+ Part A) and e-form resubmission deadlines falling between June 21 and 30 to July 10, 2026, with cancelled forms reopenable on an MCA Helpdesk request.

The mistake we see most: “we took no deposits, so DPT-3 does not apply”

This is the single most common DPT-3 error, and it catches early-stage companies in particular. DPT-3 is not just a deposits return. It is an annual return that also captures amounts received that are not considered deposits, and that category sweeps in arrangements almost every private company has. You must file for FY 2025-26 if, as on March 31, 2026, your company (other than a government company) had any of these outstanding:

• Loans from directors out of their own funds, or from shareholders where permitted
• Inter-corporate loans, including from a holding, subsidiary or associate company
• Advances received against supply of goods or provision of services
• Money from banks, financial institutions, or external commercial borrowings
• Any other receipt of money exempt from the definition of “deposit”
• Actual deposits accepted under Sections 73 to 76

For a funded startup this is rarely a “no”. Founder loans to bridge runway, advances from customers, an inter-company balance with a group entity: each one pulls you into DPT-3. The only companies genuinely outside it are those with a completely clean balance sheet, no loans, no advances, no borrowings, as on March 31. That is rare. When in doubt, file. A nil-position confirmation is far cheaper than a penalty.

What missing July 31 actually costs

Two consequences follow a late filing. First, additional fees under the Companies (Registration Offices and Fees) Rules, 2014 apply on a sliding slab by length of delay, rising to as much as 12 times the normal filing fee, calculated from June 30, 2026. Second, Rule 21 of the Deposits Rules provides a penalty of up to Rs 5,000 on the company and every officer in default, plus up to Rs 500 for every day a default continues. For a company carrying directors’ loans across multiple years, those numbers compound quietly.

A clean five-step close-out

1. Confirm applicability. Scan your March 31, 2026 balance sheet for loans, advances and any receipt of money. If anything is outstanding, DPT-3 applies.
2. Classify the figures. Split each amount between “deposits” and “amounts not considered deposits”. The form requires this split.
3. Get the auditor’s certificate where the return covers deposits, and arrange it early rather than at the wire.
4. Reconcile the DPT-3 numbers to your audited or provisional figures as on March 31, 2026.
5. File well before July 31 and keep the SRN and challan as proof of timely, penalty-free compliance. Given the portal restoration context, do not bank on the last day.

The bottom line: the MCA gave you a month, not a pass. June 30 still anchors any later penalty, and DPT-3 reaches far more companies than the word “deposit” suggests. Confirm applicability, classify correctly, and file inside the window.

Download the full DPT-3 deadline carousel (PDF) for a slide-by-slide summary you can share with your board and finance team.

Unsure whether your directors’ loans, inter-corporate balances or advances pull you into DPT-3, or want a quick review of your June and July MCA compliance calendar? Get Expert Guidance. Book a quick call: https://calendly.com/asbanka-info/30min

CA Adityavikram Banka, Founder, A S Banka Advisors Private Limited.

This article is for general information and reflects MCA General Circular No. 02/2026 dated June 19, 2026 and the related relief measure dated June 20, 2026, read with the Companies Act, 2013 and the Companies (Acceptance of Deposits) Rules, 2014. Verify the exact terms and any later updates against the official circulars on mca.gov.in before acting.