Assuming you can still file on the old MCA portal: What the June 30 MCA21 V2 shutdown actually requires

Assuming you can still file on the old MCA portal: What the June 30 MCA21 V2 shutdown actually requires

A founder opens the MCA portal on the first week of July to push through a pending AOC-4 from last year, expecting the same V2 screens they used in 2024. The forms are gone. The legacy MCA21 V2 e-filing environment is being permanently decommissioned on 30 June 2026, and every company form has already moved to the MCA21 V3 portal. Founders who assume "I will just file it on the old portal later" are about to discover that the old portal no longer exists — and that the Rs.100-per-day late fee under the Companies Act has been running the whole time, uncapped.

This is not a cosmetic change. It alters how you log in, which digital signature you need, how forms are bundled, and — critically — it coincides with the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), a limited-window penalty-relief scheme that closes the door on cheap remediation once it lapses. Here is what the law actually requires, what it costs to get this wrong, and exactly what to do in the next nine days.

What the law actually requires

Three statutory obligations collide at the end of June, and none of them is suspended just because the portal is changing.

Annual return — Section 92, Companies Act 2013. Every private limited company must file its annual return in Form MGT-7 (or MGT-7A for small companies and OPCs) within 60 days of the AGM. The signing and certification requirements in Section 92(1) and 92(2) do not change with the portal; only the filing surface does.

Financial statements — Section 137, Companies Act 2013. A company must file its audited financial statements in Form AOC-4 (or AOC-4 XBRL / AOC-4 CFS where applicable) within 30 days of the AGM. Section 137(3) is the penalty provision and it bites both the company and every officer in default.

The fee and late-fee regime — Section 403, Companies Act 2013. Section 403 read with the Companies (Registration Offices and Fees) Rules, 2014 is the section founders forget. Any document required to be filed on payment of a prescribed fee may be filed within the time specified; a delayed filing attracts an additional fee of Rs.100 per day with no upper ceiling. For belated annual filings the additional fee can run at higher multiples of the normal fee. The portal migration does not pause Section 403 — the clock keeps running on the statutory due date, not on whichever portal happens to be live.

The MCA e-Governance Cell has indicated a narrow 30-day grace window to 30 July 2026 during which late filings will not attract the Section 403 additional fee — but only where the delay is attributable to a documented V3 technical issue and only for forms whose statutory due date falls between 1 and 30 July 2026. This is a relief for genuine portal glitches, not a general extension. If your due date already passed, the grace window does nothing for you.

On top of all this sits CCFS-2026 (General Circular No. 01/2026), a one-time facilitation scheme that allows companies to regularise certain defaulted filings with a substantial waiver of additional fees during a defined window. It is the cheapest route to clean up old non-compliance — but it is time-bound, and it runs on the V3 portal.

Practical implications

Ignoring the migration produces consequences that are automated, cumulative, and personal.

The additional fee under Section 403 is mechanical. It is calculated by the system, not negotiated. A single AOC-4 that is 200 days late carries Rs.20,000 in additional fee on top of the normal fee — per form, per year. Stack MGT-7 on top and multiply across two missed financial years, and a founder who "meant to get to it" is staring at a five-figure liability that grows every day the form sits unfiled.

Persistent default triggers director disqualification under Section 164(2). If a company fails to file financial statements or annual returns for any continuous period of three financial years, every director of that company is disqualified for five years and cannot be reappointed to that company or appointed to any other. MCA21 v3 flags this automatically against the DIN — there is no human discretion and no warning letter that resets the clock.

Default also attracts penalty under Section 137(3) and Section 92(5): the company and every officer in default face penalties that begin at Rs.10,000 and increase by Rs.100 per day of continuing default, subject to statutory caps (Rs.2,00,000 for the company and Rs.50,000 for an officer in default for annual-return default under Section 92(5)). Adjudication happens under Section 454 before the Registrar/adjudicating officer, and the order is published.

MCA21 v3 raises the stakes operationally because of linked filing. In V3, several forms must be uploaded together — AOC-4 is commonly linked with MGT-7/MGT-7A, and certain event-based forms must be filed alongside their parent form. A standalone upload that worked on V2 will simply fail on V3, which means founders who wait until the last day frequently cannot complete the filing in one sitting. V3 also mandates Class 3 digital signature certificates only and requires every signatory to complete director/associate registration on the V3 portal before a form can be signed and submitted. If your DSC is Class 2, or your director has never registered on V3, you cannot file at all until that is fixed — and DSC procurement is not a same-day exercise.

The most under-appreciated consequence is strike-off under Section 248. The Registrar has the power to remove a company name from the register where it has not commenced business or is not carrying on operations — and persistent non-filing of annual returns and financial statements is precisely the signal MCA21 v3 uses to identify dormant or defaulting companies. A strike-off notice arrives as Form STK-1 (to the company) or STK-5 (public notice), and once the name is struck off, the company ceases to exist as a legal person: bank accounts are frozen, contracts become unenforceable in the company name, and directors must pursue restoration before the National Company Law Tribunal under Section 252 — a process that costs far more in time and fees than the original filing ever would have. Founders who treat the portal migration as a reason to delay are walking straight into the population the Registrar scans first.

There is also a cluster of due-date-driven forms that founders forget are separate from the annual financials. DIR-3 KYC (or the web-based DIR-3 KYC-WEB) must be filed annually for every DIN holder, normally by 30 September, and a lapsed DIN attracts a Rs.5,000 reactivation fee and is marked "Deactivated due to non-filing of DIR-3 KYC" — which means that director cannot sign any V3 form until it is restored. DPT-3, the annual return of deposits and amounts not considered deposits, is due by 30 June each year for the preceding financial year, and CSR-2 carries its own separate post-transition filing guidance for companies that cross the CSR thresholds. Each of these is filed on V3, each carries its own additional fee on delay, and none of them is covered by simply filing AOC-4 and MGT-7.

Step-by-step: what to do before June 30

• Create or migrate your V3 login today. Register as a Business User on the MCA21 V3 portal and complete director/associate registration for every signatory. Your V2 credentials do not carry over automatically.
• Verify every signatory holds a valid Class 3 DSC mapped to their DIN/PAN on V3. If anyone is on a Class 2 certificate or an expired DSC, order a replacement immediately — this is the most common last-minute blocker.
• List every pending form by statutory due date, not by portal availability. Pull your filing history and identify any unfiled AOC-4 (Section 137), MGT-7/7A (Section 92), DIR-3 KYC, DPT-3, and CSR-2 (which has separate post-transition filing guidance). Note the exact due date for each — that date drives the Section 403 fee.
• File anything already overdue now, before 30 June, rather than gambling on the July grace window. The grace window only covers due dates of 1–30 July 2026 and only documented technical failures.
• Assess CCFS-2026 eligibility for old defaults. If you are carrying multi-year defaults, evaluate whether the scheme additional-fee waiver applies to your forms and file within its window — it is materially cheaper than paying full Section 403 fees later.
• Use linked filing correctly. Prepare AOC-4 and MGT-7/7A together; do not attempt standalone uploads of forms V3 expects to be bundled.
• Download the SRN and challan for every submission and reconcile against your compliance calendar. Keep the V3 acknowledgement — it is your evidence of timely filing if an adjudication notice ever arrives.

FAQ

Can I still file my pending forms on the V2 portal before June 30?
No. Company e-filing on V2 was disabled in 2025 when the 38 forms migrated; all company forms are filed on V3 now. June 30, 2026 is the permanent decommissioning of the legacy environment. Plan every filing on V3.

Does the July 30 grace period mean my late fee is waived?
Only in a narrow case. The 30-day grace window to 30 July 2026 waives the Section 403 additional fee solely for forms with a statutory due date between 1–30 July 2026 and where the delay is caused by a documented V3 technical issue. It does not help forms that were already overdue before July.

My company has not filed for two years. What happens at three?
Section 164(2) disqualifies every director for five years once a company fails to file financial statements or annual returns for three continuous financial years. The disqualification is automatic on MCA21 v3 and blocks you from being a director in any company. Use CCFS-2026 now to regularise before you cross that line.

What is CCFS-2026 and should I use it?
The Companies Compliance Facilitation Scheme, 2026 (General Circular No. 01/2026) is a time-bound scheme allowing companies to clear certain defaulted filings with a significant waiver of additional fees. If you have legacy defaults, it is usually the cheapest path to compliance — but it is a closing window, so act within its defined period.

Closing

The portal change is not the risk — the assumption that nothing has changed is. Between Section 92, Section 137, and an uncapped Section 403 fee that never stopped running, the cost of a missed filing only goes one direction. For a compliance audit of your company, visit pvtltd.co.