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What does a new company file with the Registrar in its first year?

By CS Deepa Sharma Updated

In its first weeks a company holds a board meeting within 30 days of incorporation, the board appoints the first auditor within 30 days, and the company files Form ADT-1 within 15 days of that appointment. The year’s financial statements go in Form AOC-4, and the annual return goes in Form MGT-7 or Form MGT-7A.

What is done in the first month?

The certificate of incorporation is already the company’s proof of registration. PAN and TAN are allotted with that certificate when the company was incorporated in SPICe+. The first board meeting is within 30 days. If the board does not appoint the first auditor in 30 days, the members do so within 90 days. The steps that sit with incorporation, including the declaration before the company commences business, are on the post-incorporation page. The auditor’s notice is on the ADT-1 page.

Which annual forms follow?

The first annual general meeting is held within nine months of the end of the first financial year. A later annual general meeting is held within six months of the end of the financial year. AOC-4 is filed within 30 days of that meeting, and MGT-7 within 60 days. A small company and a one person company file MGT-7A, not MGT-7. A one person company does not hold an annual general meeting. Its AOC-4 is within 180 days of the year end, and its MGT-7A is within 60 days of the deemed adoption of the financial statements.

A small company and a one person company do not attach a cash-flow statement. Books of account are kept for eight years. A change of director is Form DIR-12. A change of registered office is Form INC-22. A change of authorised capital is Form SH-7. The yearly set, after the first year, is on the private-company page.

If a company fails to file the annual return, section 92(5) imposes a penalty of ₹10,000 and a further ₹100 for each day the failure continues, capped at ₹2 lakh for the company and ₹50,000 for an officer. Section 137(3) is the matching penalty for financial statements that are not filed. Those figures are penalties in the Act. They are not a table of additional filing fees.

How many board meetings are held?

A company that is not a small company, and is not a one person company, holds at least four board meetings a year, with not more than 120 days between them. A small company holds one meeting in each half of the calendar year, and the gap is at least 90 days. The small-company test in force is paid-up capital up to ₹4 crore and turnover up to ₹40 crore. Both limits apply. That test is on the small-company page. A one person company with only one director records decisions in the minute book under section 122. Meetings are on the board-meetings page.

Director KYC is not an annual filing due on 30 September. From 31 March 2026 it is Form DIR-3 KYC Web, by 30 June of every third consecutive financial year, with a filing within 30 days when the mobile number, email address, or residential address changes. The KYC page states that rule.

Frequently asked questions

Four questions cover board meetings, the auditor, director KYC, and a one person company.

Does every private company hold only two board meetings?

No. A small company, and a one person company with more than one director, holds one meeting in each half of the calendar year, at least 90 days apart. Any other company holds four meetings a year.

Is the auditor ratified at every annual general meeting?

No. The yearly ratification was removed. The first auditor is appointed by the board within 30 days. A later auditor is appointed by the members, usually for five years. ADT-1 follows each appointment.

Is director KYC due on 30 September?

No. From 31 March 2026 the intimation is Form DIR-3 KYC Web, by 30 June of every third consecutive financial year. A missed intimation is filed with the additional government fee. This page does not state that fee as ₹5,000.

Does a one person company hold an annual general meeting?

No. It files AOC-4 within 180 days of the financial year end and MGT-7A within 60 days of the deemed adoption of the financial statements.

Sources

The first auditor is section 139. Financial statements are section 137 and the annual return is section 92. A small company’s meetings are section 173. Director KYC is the rule in force from 31 March 2026.

  1. What a private company must do after incorporation
  2. Form ADT-1
  3. How often DIR-3 KYC is filed
  4. What the small company definition is