Private Limited Company Compliance Checklist for FY 2026-27

Staying Compliant: Private Limited Company Obligations for FY 2026-27

As the new financial year begins, private limited companies must adhere to a structured compliance framework set by the Companies Act, 2013 and allied laws. This framework outlines various one-time, periodic, annual, and event-based obligations that companies must fulfill.

• Defaulting companies can regularize pending filings between April and July 2026 under the CCFS 2026 scheme.
• Newly incorporated companies must file commencement of business declarations within 180 days.
• Annual obligations include statutory audit, AGM by 30 September, filing of financial statements and annual return with ROC, auditor appointment, and deposit returns.

Directors also have specific obligations, such as annual disclosures, DIN KYC updates, and meeting attendance. Maintaining audit trails, statutory registers, and complying with CSR reporting, FEMA filings, and POSH annual reports are essential for private limited companies. Understanding these obligations is crucial for companies to ensure continuous governance, transparency, and accountability.

The compliance framework for private limited companies for FY 2026–27 under the Companies Act, 2013 and allied laws sets out a structured mix of one-time, periodic, annual, and event-based obligations. It includes a special CCFS 2026 scheme allowing defaulting companies to regularise pending filings between April and July 2026. Newly incorporated companies must file commencement of business declarations within 180 days. Regular compliance includes quarterly board meetings, half-yearly MSME payment returns, and share capital reconciliation for demat companies. Annual obligations cover statutory audit, AGM by 30 September, filing of financial statements and annual return with ROC, auditor appointment, and deposit returns. Companies must also maintain audit trails, statutory registers, CSR reporting, FEMA filings, and POSH annual reports where applicable. Directors have separate obligations like annual disclosures, DIN KYC updates, and meeting attendance. Overall, the regime ensures continuous governance, transparency, and accountability through time-bound corporate, financial, and regulatory compliance requirements.

ANNUAL COMPLIANCES TO BE COMPLIED BY A PRIVATE LIMITED COMPANY/ ITS DIRECTORS UNDER COMPANIES ACT, 2013 and ALLIED LAWS FOR FINANCIAL YEAR 2026-27

Requirement Description Timeline One-time Compliances CCFS Scheme [only for Defaulting Companies] CCFS-2026 (Companies Compliance Facilitation Scheme) is a one-time compliance window introduced by the MCA to enable DEFAULTING companies to regularize pending statutory Annual filings i.e., FIling of Financial Statements & Filing of Annual Return by

Companies Starts: 15th April 2026

Ends: 15th July 2026 Post Incorporation Compliances Intimation of Commenceme nt of Business [for newly incorporated Companies] Declaration of commencement of business to be notified to ROC/MCA to be able to commence business immediately upon incorporation Quarterly Compliances Conducting Board Meetings A minimum of Four (4) Board Meetings shall be held in each calendar year, whether or not there is any business activity in a Company. Virtual Meetings are also allowed to be held Time Gap between two Board Meetings shall not be more than 120 days.

Best practice would be to hold one BM each calendar quarter. Half Yearly Compliance by Company Return of dues to MSME All Companies who get supplies of goods & services from Micro and Small Enterprises and whose payment to such suppliers is due for more than 45 days By 30th April [For period October to March]

By 31st October [For period April to September] Reconciliation of Share Capital Audit Report It is mandatory for every private company whose shares are in Demat form to verify that the total dematerialized (Demat) shares and physical shares align with the total

issued/listed capital By 30th May [For period October to March]

By 29th November [For April to September] Annual Compliance by Company Statutory Audit of Accounts Every Company shall prepare its Accounts and get the same audited by a Chartered Accountant at the end of the Financial Year compulsorily, get it filed with ITD and ROC/MCA Audited Annual accounts to be:

Prepared max by August 31, 2026

Approved by Board, Shareholders by 5th September, 2026

Filed with the Income Tax Department by 30th September and

Filed with RoC with 30 days of Shareholders’ AGM. Holding Annual General Meeting (AGM) It is mandatory for every Private Limited Company to hold an AGM every Year By 30th September of every year

The time gap between two AGMs shall not be more than 15 Months Appointment of Statutory Auditor The Auditor will be appointed for Five

(5) years at the AGM and the Return of Appointment of Auditor to be filed with ROC Appointment / Re-appointment of Auditors to be approved by Board & Shareholders by 5th September, 2026 ideally, and;

Return of Appointment of Auditor to be filed Filing of Annual Report (Financial Statements etc) with RoC The Company is required to file its Annual Report which includes Balance Sheet, Profit and Loss Account, Cash flow (if applicable), Auditors’ Report and Directors’ Report for the period 1st April to 31st March Annual Report to be filed on/ Filing of Annual Return with RoC The Company is required to file its Annual Return for the period 1st April to 31st March  

To be filed Return of Deposits/ Transactions not considered

as Deposits Every Company shall file a return of deposits/ outstanding receipt of money or loan by a company but not considered as deposits  

By 30th June every year  

Audit Trail Every Company shall mandatorily maintain an audit trail throughout the year for the transactions impacting the

books of accounts  

Round the year Compliance while preparation of accounts Event Based Compliances Filing of Declaration of Significant Beneficial

Ownership The Company is required to file the details of the Significant Beneficial Owner in case it has a Company of Body Corporate as shareholder with

more than 10% holding One time Compliance and

Maintenance of Statutory Registers and Records A Private Limited Company has to maintain various statutory registers and records such as the Register of shares, Register of Members, Register of Directors, Register of Charges etc As soon as the respective transaction takes place, entry has to be made in the respective registers maintained

for that purpose.  

Appointment of Cost Auditor Wherever cost audit is applicable, the Company shall return an Appointment of Cost Auditor Appointment of Secretarial Auditor Wherever cost audit is applicable, the Company shall return an Appointment of Secretarial Auditor  

Appointment of Internal Auditor Wherever cost audit is applicable, the Company shall return an Appointment of Internal Auditor Filing of Cost Audit Report Wherever cost audit is applicable, the Company shall file the Cost Audit Report Filing of Report on Corporate Social

Responsibility Every Company which is required to spend CSR, shall file a Return as an addendum By 31st March of the next year  

Other event based compliances Besides Annual filings and other compliances, there are various other compliances which need to be done as and when any event takes place in the Company Different forms are required to be filed with the Registrar for all various events within the time specified period for each such event. Compliance by Directors Each director to submit to the Company a declaration disclosing his/ her ownership/ shareholding/ directorships in other Companies, firms or other entities (whether in India or outside India) On 1st April every year or ideally before the 1st Board Meeting of the FY Each Director to submit to the Company a declaration stating that they he/ she is not disqualified from holding Directorship On 1st April every year or ideally before the 1st Board Meeting of the FY KYC of each Director to be updated with ROC even if no change, each year and whenever there is a change Routine KYC:

Once in every 3 (three) consecutive financial years & by 30th June of the year immediately following the third financial year.

When there is a change in KYC records: Each Director shall attend at least one Board Meeting every calendar year. One meeting per Calendar Year All Directors except Non Resident Directors shall give declarations as and when the Director lends unsecured

loans to the Company, not from borrowed sources As and when the unsecured loan(s) is lent by the Director(s) Compliances under other Acts Return of Foreign Assets & Liabilities under Foreign Exchange Management Act, 1999

(FEMA) Every Company having outstanding foreign Assets and Liabilities as on 31st March is required to file a return with RBI named FLA Return By 15th July of that FY Annual Report under POSH Act, 2013 Every Company having 10 or more employees with at least one woman employee shall constitute an ICC and submit an annual report to the District

Officer in every calendar year By 31st January for every calendar year for the preceding the calendar year

Readers should treat this as a tax and compliance update, not as personal advice.

This article is for general information based on available source information. It should not be considered legal, tax, investment, or financial advice.