Event-Based Filings (ADT-1, DPT-3, MGT-7, AOC-4) — What to Get Right Before You Start
Not every MCA filing waits for the financial year-end. The moment your company appoints an auditor, takes a director loan, creates a charge on a bank facility, allots shares, or changes a director, the Companies Act 2013 starts a clock — and most of these clocks run to 15, 30, or 60 days, not months.
What You're Really Buying
Event-based filings are MCA/ROC forms that a company must file not because of the calendar, but because a specific corporate event has occurred. This is distinct from annual filings such as AOC-4 (financial statements) and MGT-7 (annual return), which are due once a year regardless of whether anything eventful happened. Event-based filings are triggered by actions the company takes or facts that change: appointing or replacing an auditor (ADT-1), accepting deposits or director loans that must be reported (captured in the annual DPT-3 return due by 30 June), creating, modifying, or satisfying a charge on company assets (CHG-1/CHG-4/CHG-9), a director's appointment, resignation, or change in designation (DIR-12), allotment of new shares (PAS-3), a change in registered office (INC-22), amendment of the Memorandum or Articles of Association (MGT-14), or an increase in authorised share capital (SH-7).
For the full scope, current process and what PNPC includes, see the dedicated Event-Based Filings (ADT-1, DPT-3, MGT-7, AOC-4) service page.
Signs This Applies to You
- A new auditor is appointed, or the existing auditor resigns, is removed, or is not reappointed at the AGM — the company files ADT-1 for the new appointment, a resigning auditor files ADT-3 itself, and removal before the end of the term needs prior Central Government approval applied for in ADT-2
- The company accepts a loan from a director, an inter-corporate loan, or any receipt that must be reported under the Deposit Rules — contributes to the annual DPT-3 return
- A bank or NBFC sanctions a loan secured against company assets, or an existing charge is modified, released, or fully repaid — CHG-1, CHG-4, or CHG-9 is triggered
Before You Assume You Need This
- Routine annual filings with no underlying event — AOC-4 and MGT-7 filed after every AGM are covered under PNPC's Annual Compliance retainer, not this event-based service, though PNPC coordinates both under one calendar
- Income-tax return filing (ITR-6) and tax audit — these are Income-tax Act obligations tracked separately, though PNPC often bundles them with MCA compliance for the same client
- GST returns and TDS returns — recurring monthly/quarterly tax filings with no MCA nexus
Questions We're Actually Asked
What exactly is an 'event-based filing' — how is it different from an annual filing?
An annual filing is due once a year regardless of what happened in the company — AOC-4 (financial statements) and MGT-7 (annual return) are the classic examples, tied to the AGM date. An event-based filing is triggered by something the company does or that happens to it — appointing an auditor, taking a loan secured by company assets, allotting shares, changing a director, or amending the Articles. The deadline for an event-based filing runs from the date of that specific event, not from the financial year-end, and the windows are usually much shorter — 15 or 30 days rather than months.
The service name mentions ADT-1, DPT-3, MGT-7, and AOC-4 together — are all four really 'event-based'?
Not precisely, and we are explicit about this distinction with clients. ADT-1 (auditor appointment) is a genuine event-based filing — it fires whenever an auditor is appointed, whether at incorporation or mid-term. DPT-3 (deposits and loans return) is filed once a year by 30 June, but the underlying obligation is driven by events — every loan or deposit received during the year — so it sits between the two categories and needs event-level tracking even though the filing itself is annual. MGT-7 (annual return) and AOC-4 (financial statements) are, strictly speaking, annual filings tied to the AGM, not standalone events — PNPC manages these under the Annual Compliance retainer, coordinated with event-based filings so nothing falls through the gap between the two services.
What happens if we miss the 15-day deadline for ADT-1?
The auditor's appointment itself remains valid even if ADT-1 is filed late — the form is a notification to the Registrar, not a condition of the appointment's validity. However, an additional fee applies under the Companies (Registration Offices and Fees) Rules as a multiple of the normal filing fee that rises in slabs with the length of the delay (higher multiples for some repeat defaults), and the company should not treat late ADT-1 filing as a routine matter, since repeated defaults draw regulatory attention. PNPC files ADT-1 within the 15-day window as a standard part of every audit engagement, precisely to avoid this becoming an issue.
Getting This Right From the Start
Speak with a PNPC Chartered Accountant before your next Board resolution is signed. We will tell you exactly which MCA filings it triggers, by when, and what it will cost — in writing, before any engagement begins.
PNPC Global has advised Chennai, Bangalore and Hyderabad businesses since 1986. Explore the full Corporate Law practice for related services, or go straight to the Event-Based Filings (ADT-1, DPT-3, MGT-7, AOC-4) page for specifics.
Rates, thresholds and filing dates are set by the relevant authority and revised periodically. Treat anything numeric here as "ask PNPC for the current figure," not as a quoted fact.