AOC-4 and MGT-7 for a foreign-owned Indian subsidiary: the October–November filing clock.

AOC-4 and MGT-7 due dates for a foreign subsidiary: 30 and 60 days after the AGM — 30 October and 29 November 2026 for a 30 September AGM.

The AOC-4 and MGT-7 due dates for a foreign subsidiary are the same as for any other Indian company: AOC-4 within 30 days of the annual general meeting, MGT-7 within 60 days of it. For a company that held its AGM on 30 September 2026, that means AOC-4 by 30 October 2026 and MGT-7 by 29 November 2026. A wholly-owned subsidiary of a foreign parent does not get a softer deadline — it is an Indian company, and the Registrar of Companies treats it like one.

This trips up foreign parents more than any other filing, because the group calendar runs on the parent's financial year and audit, while the Indian subsidiary runs on India's April–March year, a September AGM and an October–November ROC clock.

What each form is

AOC-4 files the subsidiary's audited financial statements — balance sheet, profit and loss, auditor's report and board's report — with the Registrar. A company with subsidiaries of its own files AOC-4 CFS for consolidated statements; a company meeting the XBRL thresholds files AOC-4 XBRL.

MGT-7 is the annual return: shareholding, directors, changes during the year. Small companies and one-person companies file the shorter MGT-7A instead, but a foreign-owned subsidiary is generally not a small company — the definition excludes a company that is a subsidiary, so most foreign subsidiaries file the full MGT-7.

The dates for FY 2025-26

• AGM — by 30 September 2026 (first AGM of a new company gets a longer window)
• AOC-4 — within 30 days of the AGM → 30 October 2026 for a 30 September AGM
• MGT-7 / MGT-7A — within 60 days of the AGM → 29 November 2026 for a 30 September AGM

The clock counts from the date the AGM was actually held. If the Registrar granted an extension of the AGM, count 30 and 60 days from the extended meeting.

The fee-waiver nuance

As reported, MCA General Circular 05/2026, dated 24 October 2026, waives the additional (late) fee on these filings for FY 2025-26: AOC-4 and its variants (CFS, XBRL, NBFC Ind AS) can be filed without the additional fee up to 31 December 2026, and MGT-7/MGT-7A up to 31 January 2027. Read this carefully: a fee waiver is not an extension of the statutory due date. The 30-day and 60-day limits still define when the form is due — 30 October and 29 November 2026 for a 30 September AGM — and GC 05/2026 does not move them. The waiver only removes the additional-fee penalty if you file inside its window; miss the window and, as reported, the additional fee runs at ₹100/day from the original due date, not from the end of the waiver period. Confirm the circular's exact text on the MCA portal before relying on it — the same lesson as the recently-closed ROC filing amnesty.

What else lands in the same window

A foreign subsidiary's October–November is rarely just two forms. ADT-1 (auditor appointment) follows an AGM that appoints or reappoints the auditor. DIR-3 KYC for every director falls earlier but is often outstanding. And the FLA return to the RBI — foreign liabilities and assets — is a July filing that companies on provisional figures revise by 30 September. Getting the India back office to run these on India's calendar, not the group's, is half the battle; we set out what that back office actually needs to cover.

FAQ

Does a wholly-owned foreign subsidiary file MGT-7 or MGT-7A? Generally the full MGT-7. The small-company definition that lets a company use MGT-7A specifically excludes subsidiaries, so a foreign-owned subsidiary does not qualify.

What does late filing cost? Additional fees accrue at ₹100 per day per form with no cap, on top of the normal fee — which is why a missed AOC-4 or MGT-7 gets expensive quickly. GC 05/2026's waiver window, where it applies, suspends only this additional fee for filings made inside it, not the underlying due date.

Does GC 05/2026 change the AOC-4 or MGT-7 due date? No. As reported, it only relaxes the additional fee for filings made by 31 December 2026 (AOC-4) or 31 January 2027 (MGT-7/7A). The statutory due dates — 30 October and 29 November 2026 for a 30 September AGM — are unchanged.

Our parent's accounts are not finalised in time — can we delay? The Indian subsidiary's statutory audit and AGM run on the Indian timetable regardless of the group close. Plan the India audit to finish ahead of the group, not alongside it; see the first-year mistakes foreign subsidiaries make.

How Advisory Monks Consulting helps

We run the annual ROC calendar for foreign-owned Indian subsidiaries end to end — AOC-4, MGT-7, ADT-1 and the FLA and director filings around them — mapped onto the group's reporting so nothing is discovered in December. Advisory Monks Consulting keeps the India entity clean on India's clock while the parent runs on its own.

By Shamik Ukil, Advisory Monks Consulting.

This article is general information, not advice. Due dates and fees change and depend on your AGM date and company type; confirm against the MCA portal or a qualified adviser before you act.

This note is general guidance, not tax or legal advice. Positions depend on your specific facts — speak with a partner before acting.