MCA DPT-3 Relief for FY 2025-26: 31 July 2026 Fee-Free Filing Checklist for Startups
MCA has provided a one-time relief window for Form DPT-3 for the financial year ended 31 March 2026. The ordinary due date is 30 June 2026, but MCA General Circular No. 02/2026 dated 19 June 2026 allows…
What changed
MCA has provided a one-time relief window for Form DPT-3 for the financial year ended 31 March 2026. The ordinary due date is 30 June 2026, but MCA General Circular No. 02/2026 dated 19 June 2026 allows companies to file Form DPT-3 for FY 2025-26 without additional fees up to 31 July 2026.
The update has been communicated by the official MCA social handle and reported with the circular text by professional tax and company-law publications. The MCA post states that General Circular No. 02/2026 dated 19 June 2026 provides relaxation in payment of additional fees for Form DPT-3 for the financial year ended 31 March 2026 (https://x.com/MCA21India/status/2068019212229226818). TaxGuru has reproduced the circular text with file number Policy-02/2/2020-CL-V-MCA and explains that the relief was issued due to MCA data-centre restoration work after the fire incident on 5 June 2026 (https://taxguru.in/company-law/mca-extends-dpt-3-late-fee-waiver-31st-july-2026-due-data-center-fire.html). The filing itself remains through the MCA portal (https://www.mca.gov.in/).
Important: this is relief from additional fees for filing up to 31 July 2026. It should not be read as permission to ignore DPT-3.
Who should check applicability
Every Indian startup incorporated as a company should check DPT-3 applicability if it had outstanding receipts of money, loans, borrowings or deposit-like balances as on 31 March 2026.
This can include:
- Private limited companies.
- Public companies.
- One Person Companies.
- Section 8 companies.
- Startups with director loans.
- Startups with inter-corporate loans.
- Startups with share application money pending allotment.
- Startups with unsecured loans, advances or other reportable receipts.
Government companies are generally treated separately, and NBFC or regulated-entity positions should be checked with specific professional advice.
Founder impact
For founders, DPT-3 is not just a ROC form. It is a balance-sheet discipline exercise. The company has to identify outstanding amounts as on 31 March 2026 and classify whether they are deposits, exempted deposits or other receipts not treated as deposits.
The risk is not only late filing. The bigger risk is wrong classification. A founder loan, friendly advance or inter-company balance may look simple in a spreadsheet but can create compliance questions if the accounting note, board approval and DPT-3 disclosure do not match.
Practical filing checklist
| Step | What to do | Owner |
|---|---|---|
| 1 | Pull trial balance and ledger balances as on 31 March 2026 | Finance team |
| 2 | Identify loans, deposits, advances and outstanding receipts | Finance and CS |
| 3 | Classify each item under deposits or exempted categories | CS or professional advisor |
| 4 | Match balances with financial statements and audit notes | Auditor and finance |
| 5 | Collect board approvals and lender confirmations where relevant | Founder office |
| 6 | Prepare DPT-3 attachments and certifications, if applicable | CS and auditor |
| 7 | File on MCA V3 before 31 July 2026 to avoid additional fees | Authorised signatory |
| 8 | Save challan, SRN, form copy and working papers in the compliance folder | Company records owner |
Documents to keep ready
- Audited or provisional financial statements for FY 2025-26, as applicable.
- Trial balance as on 31 March 2026.
- Ledger extracts for loans, deposits, advances and borrowings.
- Loan agreements and lender confirmations.
- Director declarations for director loans, where relevant.
- Board resolutions approving borrowing or acceptance of funds.
- Details of share application money pending allotment, if any.
- Auditor certificate or certification support where required.
- MCA login, DSC and authorised signatory details.
- Prior-year DPT-3 copy for comparison.
Mistakes to avoid
- Treating DPT-3 as required only when public deposits exist.
- Ignoring director loans or inter-corporate borrowings.
- Filing without reconciling the ledger to financial statements.
- Missing share application money pending allotment.
- Assuming the 31 July window removes the need for classification.
- Filing based only on memory instead of ledgers and agreements.
- Not saving the SRN, challan and filed form in the data room.
Timeline for founders
| Date | Action |
|---|---|
| 25 June 2026 | Start ledger review and transaction classification |
| 26-30 June 2026 | Resolve director loan and outstanding balance evidence |
| 1-10 July 2026 | Coordinate auditor or certification support |
| 11-20 July 2026 | Prepare and internally review DPT-3 |
| 21-31 July 2026 | File and archive proof before the relief window closes |
Founders should not wait until the last week. MCA filing traffic and DSC issues can turn a simple form into a deadline problem.
Founder action plan
- Ask finance for a list of all outstanding receipts as on 31 March 2026.
- Mark which balances are from founders, directors, group entities, investors, customers or vendors.
- Check whether any amount should have supporting board approval.
- Confirm whether the company filed DPT-3 in earlier years.
- File before 31 July 2026 if applicable and keep the evidence ready for investor diligence.
Sources
- MCA official portal: https://www.mca.gov.in/
- MCA official X post on DPT-3 relief: https://x.com/MCA21India/status/2068019212229226818
- Circular text reproduced by TaxGuru: https://taxguru.in/company-law/mca-extends-dpt-3-late-fee-waiver-31st-july-2026-due-data-center-fire.html
- Companies Act, 2013 on India Code: https://www.indiacode.nic.in/bitstream/123456789/2114/5/A2013-18.pdf
FAQ Section
What is the DPT-3 relief for FY 2025-26?
MCA has allowed Form DPT-3 for FY 2025-26 to be filed without additional fees up to 31 July 2026, although the ordinary due date is 30 June 2026.
Does the relief mean DPT-3 is optional?
No. It is only a fee-relief window for delayed filing up to 31 July 2026. Applicability and correct filing still need to be checked.
Do startups with director loans need to review DPT-3?
Yes. Director loans and other exempted receipts may need review and possible reporting depending on the facts and outstanding balances.
What date are balances checked for DPT-3?
The practical review is based on outstanding amounts as on 31 March 2026 for the relevant financial year.
What is the biggest DPT-3 mistake?
The biggest mistake is filing without classifying deposits, exempted deposits, loans and other outstanding receipts correctly.
Founder / Business Takeaway
Use the 31 July 2026 relief window to clean the classification, not to delay the work. DPT-3 is a small form with large diligence value when loans and founder funding are involved. The Best CS Firm In India mindset is to reconcile the ledger before the portal deadline.
Need expert support?
BSA helps startups review DPT-3 applicability, classify outstanding receipts, prepare supporting documents and maintain ROC compliance records.
Need expert support?
BSA supports founders across India with ROC, FEMA, due diligence, fundraising readiness, and company secretarial execution.
