MCA21 V2 Portal Goes Dark Tomorrow: Every Private Company's V3 Filing Checklist

MCA21 V2 Portal Goes Dark Tomorrow: Every Private Company's V3 Filing Checklist

Most company directors filing ROC forms this week don't know that the MCA21 portal they learned to navigate is being permanently switched off tomorrow, 30 June 2026. MCA's Phase 3 migration is complete, every remaining form has moved to V3, and any company that isn't prepared will hit rejected filings, missed deadlines, and automated compliance flags that are visible to every bank and investor doing due diligence on their company.

This is not a routine update. Here is exactly what has changed, what is at risk, and what you need to do before the window closes.

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What the V2 Shutdown Actually Means

The Ministry of Corporate Affairs built MCA21 V3 as a ground-up rebuild — different authentication architecture, form-linking logic, document upload requirements, and automated compliance tracking. The migration happened in three phases over four years:

• Phase 1 (2022–2023): Company incorporation forms moved first — SPICe+, INC-32, AGILE-PRO, and related new company registration forms.
• Phase 2 (2023–2025): Annual compliance forms including AOC-4 (financial statements), MGT-7/MGT-7A (annual return), and ADT-1 (auditor appointment) migrated to V3.
• Phase 3 (June 2026): The final batch — charge creation forms CHG-1 and CHG-9, Director KYC (DIR-3 KYC Web), miscellaneous charge and lien forms — are now live on V3 only.

From 1 July 2026, legacy V2 filing URLs redirect to V3. There is no grace period.

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The Filing Change That Will Break Your Annual Return

The single most consequential operational difference in V3 is mandatory form linkage. In V2, forms were independent. V3 enforces a dependency chain:

AOC-4 and ADT-1 Must Be Linked

Form AOC-4 will be rejected on V3 if the auditor appointment (Form ADT-1) for the current financial year is not already on record. Under Section 139 of the Companies Act, 2013, every company must file ADT-1 within 15 days of auditor appointment. Many founders skip this step. Check your MCA21 master data now.

MGT-7A Requires AOC-4 in "Submitted" Status

The annual return (MGT-7A for small companies, MGT-7 for others) now requires AOC-4 to be in "Submitted" or "Approved" status before MGT-7A can be processed. If financial statements are delayed, your annual return is automatically delayed too. Additional fees clock runs on both forms independently.

CHG-1 Requires Charge Instrument Upload

Form CHG-1 now requires a scanned copy of the charge instrument and the company PAN to be uploaded at the time of filing on V3. This was not a requirement on V2. Under Section 77 of the Companies Act, 2013, charge creation must be registered within 30 days. Failure to register means the charge is void against the liquidator and creditors in insolvency proceedings.

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DPT-3 Deadline Extended to 31 July 2026 — MCA Circular No. 02/2026

A fire at the MCA Data Centre on 5 June 2026 forced an emergency switchover to the Disaster Recovery site. MCA issued General Circular No. 02/2026 dated 19 June 2026 extending Form DPT-3 (Return of Deposits for FY 2025–26) from 30 June to 31 July 2026 without additional fees.

Your company must file DPT-3 if:

• Any director has given a loan to the company (even interest-free)


• Any shareholder has given temporary funding not classified as share capital


• The company has any unsecured loan from an individual or non-banking entity

Under Section 73 and Section 76A of the Companies Act, 2013, failure to file DPT-3 attracts penalties of ₹1 crore or twice the deposit amount, whichever is lower, plus ₹5,000 per day for continuing default. Every director faces personal liability under Rule 21 of the Companies (Acceptance of Deposits) Rules, 2014.

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CCFS-2026 Closes in 16 Days — 10% of Additional Fees

General Circular No. 01/2026 dated 24 February 2026 introduced the Companies Compliance Facilitation Scheme 2026 (CCFS-2026), open until 15 July 2026:

• File pending annual returns and financial statements at only 10% of the total additional fees. For a company with two years of missed filings, this can mean ₹40,000–60,000 instead of ₹4–6 lakh.
• Apply for dormant company status under Section 455 at half the normal fee.
• Apply for voluntary strike-off under Section 248 at 25% of filing fees.

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What Happens When You Ignore This

Director Disqualification Under Section 164(2)

Under Section 164(2)(a) of the Companies Act, 2013, if a company fails to file its annual returns or financial statements for three consecutive financial years, all directors are automatically disqualified for five years. The flag triggers automatically on MCA21, visible to banks, investors, and SEBI-regulated intermediaries.

Strike-Off Under Section 248

MCA issues notices under Section 248(1) to companies that have not filed annual returns for two or more consecutive years. On V3, the notice-to-strike-off pipeline runs faster. Restoration requires an NCLT petition — ₹50,000 to ₹2 lakh in legal fees — plus all arrear filings.

MCA21 Compliance Flag Blocks Business

A compliance flag on MCA21 means banks deny current account renewal, NBFCs reject loan applications, and investors flag the company in preliminary due diligence.

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Step-by-Step: What To Do Before 15 July 2026

• Log in to mca.gov.in on V3. Do not use legacy V2 URLs. Verify your registered user profile is active on V3.
• Check DIN and director status. Navigate to MCA21 Services → DIN Services → Verify DIN/Director Details. Confirm no disqualification flag exists against any director.
• Verify DIR-3 KYC status. MCA now operates a triennial KYC cycle — directors file DIR-3 KYC Web once every three financial years by 30 June. If KYC is due in 2026, file today — the deadline is today.
• Audit ADT-1 status. Confirm Form ADT-1 for the current auditor and FY is on record. File it before attempting AOC-4 if it is missing.
• Assess DPT-3 requirement. If any director or shareholder has given loans in FY 2025–26, file DPT-3 on V3 by 31 July 2026.
• Check all pending annual filings. Identify missing AOC-4 or MGT-7/MGT-7A. Use CCFS-2026 to file at 10% of additional fees before 15 July 2026.
• Test form linkage before deadline day. Do a preview run on V3 to verify the AOC-4 → MGT-7A dependency chain is satisfied before the actual filing deadline.
• Brief your CS or CA today. Confirm your professional has tested V3 filing flows and is aware of the form linkage and document upload requirements.

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FAQ

Q: Our company hasn't filed AOC-4 for FY 2024–25. What is the penalty and does CCFS-2026 apply?

A: For a March year-end company, AOC-4 for FY 2024–25 was due by 30 October 2025. Additional fees have been accruing. CCFS-2026 allows you to file by 15 July 2026 at 10% of accumulated additional fees. File immediately.

Q: We have a ₹10 lakh director loan to the company from 2024. Do we need DPT-3?

A: Yes. Director loans to the company — even informal or partially repaid — must be disclosed in Form DPT-3 annually under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. Extended deadline: 31 July 2026. Penalty for non-filing: up to ₹1 crore or twice the amount, plus ₹5,000 per day.

Q: The V2 portal is gone. Can I still access old filings and company data?

A: Yes. Go to mca.gov.in → MCA21 Services → Company/LLP Master Data → search by CIN. All historical filing data, charges, and director records remain accessible on V3.

Q: A director of our company received a disqualification notice. What can we do?

A: There is no administrative remedy. File a writ petition before the jurisdictional High Court. Simultaneously file all pending returns under CCFS-2026. The five-year bar runs from the date the trigger condition was met, not the notice date.

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The Bottom Line

The MCA21 V2 shutdown, the CCFS-2026 window closing 15 July, and the DPT-3 extension to 31 July all land in the same month. The MCA is pushing companies to regularise before V3's automated enforcement runs at full scale. A company that is compliant going into August 2026 benefits from improved services. One that is not faces a system faster, more automated, and less forgiving than its predecessor.

For a compliance audit of your company, visit pvtltd.co.

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