Form AOC-4: Filing Financial Statements with the Registrar

Who files AOC-4 and which version

Every company registered in India files its financial statements with the Registrar each year, including dormant companies, Section 8 companies and OPCs. Most companies use the standard AOC-4. Companies within the XBRL classes, such as listed companies or those with paid-up capital of ₹5 crore or turnover of ₹100 crore, use AOC-4 XBRL instead. Holding companies also file consolidated statements in AOC-4 CFS.

NBFCs that follow Ind AS have their own variant, AOC-4 NBFC (Ind AS). Companies covered by the CSR provisions attach the CSR report in CSR-2 as an addendum. Choosing the right variant first saves time, because data entered in one form cannot be moved to another.

Due date explained

The AGM must be held within six months of the financial year-end, so by 30 September for a March year-end, and AOC-4 is due 30 days after the AGM. For FY 2025-26, an AGM on 30 September 2026 means AOC-4 is due by 30 October 2026. If the AGM is held earlier, the deadline moves earlier too.

An OPC does not hold an AGM and must file within 180 days from the close of the financial year, so by 27 September for a March year-end. If the financial statements are not adopted at the AGM, unadopted statements must still be filed within 30 days of the AGM, followed by the adopted ones within 30 days of the adjourned meeting.

Attachments

The financial statements attached must be the same signed set approved by the board and laid at the AGM. Each attachment is uploaded as a PDF, and the auditor's report must carry a valid UDIN. The list below covers the usual set for a private company.

• Balance sheet, statement of profit and loss and notes
• Cash flow statement, except for OPCs, small companies and dormant companies
• Directors' report with annexures
• Independent auditor's report and CARO report where applicable
• AOC-1 for subsidiaries, associates and joint ventures
• AOC-2 for related-party contracts, where applicable
• Secretarial audit report (MR-3), where applicable
• RoC approval of AGM extension, if any

Fees, late fee and penalties

The normal fee follows the nominal-capital slab: ₹200 below ₹1 lakh up to ₹600 at ₹1 crore and above. AOC-4 is excluded from the multiple-based additional fee. Instead, a delay attracts ₹100 per day with no upper limit, so a year's delay adds about ₹36,500 to each form.

Section 137(3) adds a penalty. The company is liable to ₹10,000 plus ₹100 per day of continuing default, up to ₹2 lakh. The managing director, CFO or, if none, any director in default faces ₹10,000 plus ₹100 per day, up to ₹50,000. Under Section 164(2), failure to file financial statements or annual returns for three continuous financial years disqualifies the directors for five years.

Common reasons for resubmission

Typical problems are figures in the form that do not tie to the attached statements, an auditor's UDIN that is missing or invalid, a wrong AGM date, missing AOC-1 where the company has subsidiaries, and unsigned PDFs. Choosing AOC-4 when the company falls in an XBRL class is another frequent error. Check the auditor details against the latest ADT-1 before filing. Refogo's partner professionals can prepare and file AOC-4 as part of annual compliance for a fixed fee.

Step by step

1. 1Finalise accounts

   Board approves the financial statements and directors' report; the auditor signs with UDIN.

2. 2Hold the AGM

   Lay the financial statements before members and record the adoption.

3. 3Choose the form

   Confirm whether AOC-4, AOC-4 XBRL or AOC-4 CFS applies.

4. 4Fill AOC-4 on V3

   Enter balance sheet, profit and loss and other data and attach PDFs.

5. 5Certify and sign

   A practising professional certifies and a director or CFO signs with DSC.

6. 6Pay fee

   Pay within 30 days of the AGM to avoid ₹100 per day additional fee.