ROC Form MGT-7/MGT-7A: MCA makes uploading registered office photo now mandatory

The Ministry of Corporate Affairs (MCA) has introduced a new change for companies filing their Annual Return in Form MGT-7 or MGT-7A.

As per the new rule, it is mandatory to upload a recent photograph of the company’s registered office. The photo should clearly show the company’s name and full address board.

Many professionals are opposing this new change, as it will complicate things for small companies having a small space where putting up boards may not be easy. However as per MCA this requirement aims to enhance authenticity and physical verification of the registered office location.

This requirement is already there in the Form INC-22, a MCA Form used to notify the Registrar of Companies (ROC) about the change of registered office of a company in India. However, now the same will be reported annually with Annual Filing of the company.

Other key changes in Form MGT-7:

• Companies must now disclose a comprehensive summary of debenture-related borrowings, enhancing visibility of debt exposure by sharing a Summary of Indebtedness for Debentures.
• A detailed classification of shareholders based on ownership category (such as promoters, public, institutional, and non-institutional holdings) is now mandatory.

MGT-8 is part of MGT-7

Form MGT-8, previously a separate certification by a Company Secretary in Practice, is now embedded within MGT-7. This is applicable on companies meeting the criteria under Section 92(2) of the Companies Act, 2013—i.e., listed companies or those with paid-up capital more than Rs. 10 crore or turnover more than Rs. 50 crore. Further, the embedded MGT-8 portion includes a certification statement by the Company Secretary. While this is mostly structured, any qualifying remarks about compliance can presently be added in the Optional Attachment field.