Statutory BulletinROC Compliance & Share Allotment
ROC Compliance

FPC Annual ROC Filing Checklist: MGT-7A & AOC-4 Step-by-Step (2025-26)

Complete step-by-step ROC annual filing checklist for Farmer Producer Companies: AGM before Sep 30, AOC-4 by Oct 30, MGT-7A by Nov 30. Avoid ₹100/day late fees and DIN deactivation.

CA Hemanth, Vihara FoundationPublished 5 September 2026Updated 25 September 20266 min read

Every Farmer Producer Company must complete its statutory ROC filings within fixed windows after the AGM. Missing them means ₹100 per day per form in late fees — with no upper limit — plus risk of DIN deactivation for every director.

The Three-Step Annual ROC Window

Step 1: AGM by September 30

Hold your Annual General Meeting within 6 months of fiscal year-end (March 31). For FY 2025-26, the AGM deadline is September 30, 2026. First-year FPCs must hold their AGM within 90 days of incorporation.

AGM Notice Requirements:

  • 14 days' written notice to every member
  • Notice must include: agenda, audited accounts, board report, proposed dividend/patronage bonus
  • Quorum: minimum 1/4th of total members (or higher if specified in Articles)
  • Minutes must be recorded and signed within 30 days

Step 2: Form AOC-4 by October 30

File audited financial statements within 30 days of the AGM date. Required documents:

  • Audited Balance Sheet and Profit & Loss Account
  • Auditor's Report (signed by the statutory CA with UDIN)
  • Board's Report (signed by Chairman + 1 director, or 2 directors if no Chairman designated)
  • Related Party Transaction disclosures if applicable

Step 3: Form MGT-7A by November 29

File the abridged Annual Return within 60 days of the AGM. MGT-7A requires:

  • Principal business activities and registered office details
  • Complete list of members with shareholding (from MGT-1 register)
  • Details of all board meetings held (date, attendance)
  • Director KMP details and DIN numbers
  • Certification by a CS (Company Secretary) if turnover exceeds ₹2 Crore

Supporting Compliances That Often Get Missed

ADT-1: Auditor Appointment

If you changed or reappointed your statutory auditor at the AGM, file Form ADT-1 within 15 days of the AGM. This is separate from AOC-4 and MGT-7A and is frequently missed.

DIR-3 KYC for All Directors

Every director must file DIR-3 KYC by September 30 every year. Missing this deactivates the DIN immediately.

MBP-1: Director Interest Disclosure

Collect signed MBP-1 declarations from all directors at the first board meeting of each April. This must precede the AOC-4 filing.

Common Mistakes That Trigger Scrutiny

  1. AGM minutes not signed within 30 days of the meeting date
  2. Auditor's UDIN not generated before submission of the report
  3. MGT-1 member register not updated for new share allotments during the year
  4. Incorrect CIN quoted on AOC-4 (copy-paste error from previous year)

Vihara Foundation's Governance Academy provides pre-drafted MGT-1 registers, AGM notice templates, and board resolution formats as part of the paid Master Vault — so you never miss a filing again.

Frequently Asked Questions

Quick answers from our compliance team

What is the deadline for FPC AGM in 2026?

Every Farmer Producer Company must hold its Annual General Meeting within 6 months of fiscal year-end, i.e., by September 30, 2026, for FY 2025-26.

What happens if an FPC misses ROC filing?

Late fees of ₹100 per day per form apply with no upper cap. Non-filing for 2 consecutive years leads to DIN deactivation for all directors and risk of company strike-off under Section 248 of the Companies Act, 2013.

What documents are needed for Form AOC-4?

Form AOC-4 requires: audited balance sheet, profit & loss statement, notes to accounts, auditor's report (signed by CA), board report (signed by minimum 2 directors), and extract of Annual Return.

Is MGT-7A different from MGT-7 for Producer Companies?

Yes. Producer Companies file the abridged annual return in Form MGT-7A (not the full MGT-7). This was introduced to reduce the compliance burden for smaller companies.

Need hands-on compliance support?

Vihara Foundation runs live sessions on FPC compliance. Each session is registered for separately, with or without its recording and kit.