ICSI makes 2nd representation with MCA to Extend Due Dates for Annual Filings Amid Technical Glitches on Portal

The President of the Institute of Company Secretaries of India (ICSI), CS Dhananjay Shukla, has written a formal representation dated October 14, 2025, to Ms. Deepti Gaur Mukerjee, Secretary, MCA (Ministry of Corporate Affairs), Government of India, urging to extend the due date for filing of Annual E-forms under the Companies Act, 2013, because professionals and companies are facing major technical difficulties while using the MCA-21 Version 3 (V3) portal.

In the representation, ICSI agreed that the upgrade of MCA-21 V2 to V3 was a major digital reform launched by the government to improve the “Ease of Doing Business” and promote the Digital India initiative. However, they mentioned that despite its good intentions, the new system is currently not functioning smoothly and is acting as a bottleneck in compliance.

In this context, taxpayers and professionals across the country have been continuously sending their feedback and reporting technical glitches and errors in the portal. Earlier, the ICSI had already written to the MCA on September 29, 2025, describing these issues, and the present representation emphasises the present and ongoing challenges being faced by taxpayers.

Lengthy and Complicated e-Forms:

This year, the government has upgraded the old MCA V2 to the new system of MCA V3. Therefore, the layout and structure of forms like AOC-4 and MGT-7 have changed. Now, more information has to be typed directly into the forms instead of attaching documents. In this way, it takes about 3 to 4 hours to fill out each form. Additionally, users are finding incorrect pre-filled data in the forms, like incorrect company details or mismatched SRN numbers. In the offline version, users are facing problems in saving their progress, and wrong data gets filled automatically.

Portal Not Responding Properly:

The MCA’s upgraded version (V3) is frequently displaying errors like “Something went wrong” or “Request Timeout”. It logs out users automatically while they are working. This makes uploading forms or making payments almost impossible.

Login and Password Problems:

Several professionals are facing problems in resetting their passwords or updating their profiles because the system repeatedly shows the same error message-“Something went wrong. Please try again later.”

Frequent Digital Signature (DSC) Validation Failures:

Users with valid and registered Digital Signature Certificates (DSCs) are facing issues submitting forms as the system repeatedly displays “DSC verification failed” errors, despite repeated re-registration. After the verification message pops up, not registered.

In addition to these, ICSI also cited issues like Payment Gateway Errors, Submission and Download Errors and Portal Overload During Working Hours. ICSI also mentioned that the months of October and November are festive months in India, with many national and regional holidays. During this time, companies and professionals are left with fewer working days and limited staff. Dates of festivals overlap with compliance deadlines, which increases their workload even more.

In view of all these difficulties at the end of the representation, ICSI requested the Ministry of Corporate Affairs to kindly extend the due dates for filing the following annual forms till December 31st, 2025:

AOC-4, AOC-4 (CFS), AOC-4 (XBRL), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), DIR-12, ADT-1, MGT-7, and MGT-7A

Waiver of Additional Fees:

Provide a general waiver of late filing fees for all forms (including event-based forms) that are due between September 1, 2025, and December 31, 2025, considering the unstable condition of the portal.

Final Submission:

ICSI emphasised that company secretaries and professionals fully support the Ministry’s digital transformation efforts. However, the current technical issues are making it impossible to comply on time.

The Institute requested the MCA to extend the deadlines similar to relief measures given by other regulators and offered to provide demonstrations or detailed inputs if required.