DIR-3 KYC Default Triggers Action: ROC Slaps Penalty on Company and Directors under Section 454

ROC imposed a penalty on the company and its four directors for failing to complete mandatory DIR-3 KYC compliance and not responding during inquiry proceedings.

Non-Filing of DIR-3 KYC Costs Company

Saloni Kumari | Feb 6, 2026 |

DIR-3 KYC Default Triggers Action: ROC Slaps Penalty on Company and Directors under Section 454

DIR-3 KYC Default Triggers Action: ROC Slaps Penalty on Company and Directors under Section 454

The Registrar of Companies (ROC) Kanpur has issued an order of adjudication dated February 02, 2026, imposing a penalty amounting to Rs. 4 lakh on a company named Pillars Mutual Nidhi Limited and its four directors under Section 454 of the Companies Act 2013.

The Serious Corporate Affairs (SCA), through its meeting minutes dated April 10, 2020, of the MCA (Ministry of Corporate Affairs), instructed for an inquiry of the default company under Section 206(5) of the Companies Act, 2013. During the inquiry, the concerned officer observed from the MCA21 records that the KYC status of all the directors of the company was deactivated for non-furnishing of DIR-3 KYC. This reflected an explicit contravention of the provisions of Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014.

In conclusion to this non-compliance, penalty proceedings under Section 450 of the Companies Act, 2013, were suggested against the company and its directors in default. The Inquiry Officer mentioned the same in its report dated September 26, 2022.

Later DGCoA and the Regional Director (NR) directed the ROC Kanpur to take necessary actions against the company and its director for non-compliance with section 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014.

Further, the office noted that the company and its directors neither submitted any response nor requested any hearing in this context. Considering the same, the ROC Kanpur imposed a penalty amounting to Rs. 2 lakh on the company, Pillars Mutual Nidhi Limited, and Rs. 2 lakh on its four directors named Devi Lal Kushwaha, Deepchand Kushwaha, Rajendra Kumar, and Bhupendra Kushwaha (Rs. 50,000 on each).

Additionally, directed them all to pay the levied penalty amount and correct the default within the time period of 90 days from the date of receiving the order.

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