Director KYC (DIR-3 KYC) & DIN Reactivation

DIR-3 KYC is the identity and contact-detail verification that every holder of a Director Identification Number (DIN) must complete with the Ministry of Corporate Affairs, under Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014. Under rule 12A(1), as amended by notification G.S.R. 943(E) dated 31 December 2025, every individual who holds a DIN as on 31 March of a financial year files a KYC intimation in Form DIR-3-KYC-Web on or before 30 June of the financial year immediately following every third consecutive financial year. It applies whether or not the person is currently an active director of any company — the obligation is tied to the DIN itself, not to a specific directorship.

They no longer exist as two separate things. The earlier e-form DIR-3 KYC and the web service DIR-3-KYC-WEB have been replaced by one form, Form No. DIR-3-KYC-Web, titled 'Intimation of Changes or Reactivation of DIN'. Its listed purposes are reactivation of DIN, KYC compliance, update of mobile number, update of email ID, update of permanent residential address and update of present residential address. So the question is no longer which of two forms you qualify for, but what the single form is being filed for.

Under rule 12A(1), the routine KYC intimation on Form DIR-3-KYC-Web is filed once every three consecutive financial years, by 30 June, replacing the earlier annual filing. Separately, a change of personal mobile number, email address or residential address has its own thirty-day window (rule 12A(2)). The dates below come from the MCA's own examples. Cases the MCA's examples do not cover — a DIN allotted in another year, an irregular KYC history, or a DIN that is already deactivated — are confirmed with PNPC or the MCA. According to the MCA advisory on DIR-3 KYC Web, 30 March 2026: if you have already filed KYC for FY 2025-26 (DIN allotted on or before 31 March 2025) and your particulars have not changed, no filing is required for FY 2026-27 or FY 2027-28 and your next filing is due by 30 June 2028; if your DIN was allotted during FY 2025-26, your first filing is due by 30 June 2029 and then every third financial year; and, in the MCA's example of a DIN allotted in FY 2025-26, an update of mobile, email or address in FY 2027-28 does not change the cycle.

The amendment does not itself restate what triggers deactivation or on what date it takes effect, so we do not quote a deactivation date. What is settled is that the DIN reactivation and deactivation mechanics sit in rule 11, which the amendment updated to refer to Form DIR-3-KYC-Web, and that reactivation of a DIN is one of the listed purposes of that form. In practical terms, a DIN shown as deactivated generally cannot be used to sign MCA e-forms — not just at one company but at every company where that individual is a director, because the status attaches to the DIN, not to a single company record. If you think you may have missed a filing, ask PNPC to check your DIN's current status on MCA master data.

By filing Form DIR-3-KYC-Web with reactivation of DIN as the purpose, together with any fee that applies; confirm the current position at the time of filing. The form collects the same particulars as a KYC filing: the existing mobile number and email ID, each verified by OTP; PAN, which is verified on the form; the address; and residential proof. The DIN holder digitally signs the declaration, and the form carries a professional's certificate; whether it applies to a reactivation filing is confirmed at filing. Once MCA processes the filing and the DIN status is restored, the director can resume signing MCA forms.

No, and this distinction matters. A DIN that is deactivated for KYC reasons is an administrative status, dealt with through Form DIR-3-KYC-Web. Disqualification under Section 164(2) is a statutory consequence of a company failing to file annual returns or financial statements for three consecutive financial years, and it bars the director from being appointed or continuing as director in any company for five years. A KYC filing alone does not remove a Section 164(2) disqualification.

For a change of mobile number, email address or residential address, rule 12A(2) requires Form DIR-3-KYC-Web to be submitted within thirty days of the change, with the prescribed fee under the Companies (Registration Offices and Fees) Rules, 2014. Whether a government fee applies to reactivation is confirmed at the time of filing. Confirm the current government fee, if any, at the time of filing.

Yes. Rule 12A applies to every individual who holds a DIN, which includes NRI and foreign national directors holding an Indian DIN. The form asks for passport number where applicable. The one-time passwords go to the mobile number and email ID given on the form; if you are abroad, confirm whether an international number can be used before the filing.

The DIN holder digitally signs the declaration on the form, and the one-time passwords go to the director's own mobile number and email ID — a professional cannot substitute their own credentials for the director's identity verification. What a CA firm like PNPC does is manage the process: preparing the form, coordinating documents, providing the professional's certificate that the form carries, where the form requires it, and coordinating the OTP timing with the director. The OTP steps and the director's digital signature must be the director's own.

No. The KYC obligation attaches to the individual DIN, not to each company. A single DIN holder files once for that DIN, and the update is made to the DIN record centrally, which then applies across every company where the individual is listed as a director.

Yes. Under rule 12A(2), if your personal mobile number, email address or residential address changes, Form DIR-3-KYC-Web must be submitted within thirty days of the change, with the prescribed fee under the Companies (Registration Offices and Fees) Rules, 2014. The form asks for your existing mobile number and email ID (each verified by OTP) and the updated ones (again with OTP verification), and accepts supporting attachments, each up to 2 MB. This filing runs independently of your three-year KYC date. In the MCA's example of a DIN allotted in FY 2025-26, an update made in FY 2027-28 does not change the cycle, and the next KYC filing remains due in the April to June 2029 window.

The form collects your DIN and name; name details, nationality, date of birth, income tax PAN (verified on the form) and passport number where applicable; your existing and updated mobile number and email ID (each verified by OTP); your permanent and present residential address; and residential proof — a voter identity card, passport, driving licence, Aadhaar, bank statement or utility bill. Supporting attachments can be up to 2 MB each. Have a recent proof of address ready and confirm what the portal accepts at the time of filing.

The DIN holder digitally signs the declaration on the form, so you need a valid digital signature. The form also carries a certificate by a practising professional — a chartered accountant, cost accountant or company secretary in whole-time practice — which is likewise digitally signed. Check that your DSC is valid before the filing date.

The form carries a certificate by a practising professional (a chartered accountant, cost accountant or company secretary in whole-time practice), digitally signed, alongside the DIN holder's own digitally signed declaration. Whether every filing purpose on the form needs the certificate in the same way is something we confirm against the live form and MCA's current guidance, so ask PNPC before assuming a simple change can be filed without professional involvement.

The reactivation of DIN is one of the listed purposes of Form DIR-3-KYC-Web, and rule 11 (as updated by the amendment) refers to that form. According to an ICAI announcement on the change, directors who had not submitted KYC were able to have their DINs reactivated under the existing provisions until 31 March 2026. Confirm with PNPC or the MCA whether reactivation is still available on the same terms. Either way, confirm first that the reason for the deactivation really is KYC and not a Section 164(2) disqualification.

Indirectly, yes. While the deactivation attaches to the individual's DIN rather than to the company, any filing at the company that requires that director's digital signature — annual returns, resolutions, charge filings, director appointment or resignation forms — generally cannot be submitted until the DIN is reactivated. If the company has a filing deadline approaching and its authorised signatory's DIN is deactivated, the company's own compliance timeline is put at risk as a consequence.

Yes, this should be a standard pre-closing step. Investors and their counsel routinely verify that every signing director's DIN is active and free of disqualification flags before a transaction closes. Discovering a deactivated or disqualified DIN during diligence — rather than in advance — can delay signing.

Yes. Since the DPIN (Designated Partner Identification Number) system was merged into the DIN system, a Designated Partner of an LLP is allotted and identified by the same DIN used for company directors. Rule 12A applies to every individual who holds a DIN, so a designated partner holding a DIN falls within its wording — the requirement is tied to holding a DIN, and DIN is the common identifier across companies and LLPs.

The DIN itself does not automatically lapse or get cancelled when you resign from your last directorship. It remains on MCA's records, and an individual who holds a DIN as on 31 March of a financial year is within rule 12A(1)'s KYC intimation cycle. Many people leave a DIN dormant, which means the KYC obligation continues.

The direct obligation to file rests with the DIN holder, not the company. However, if the company itself misses its own filing deadlines — AOC-4, MGT-7, or other event-based forms — because its authorised signatory's DIN could not be used at the relevant time, the company faces its own independent late fees and penalties under the Companies Act for those missed filings. The two streams are separate but can compound each other.

Processing depends on MCA's system and on whether the filing needs any query resolution, so we do not commit to a fixed number of days. The DIN remains non-functional for signing purposes for as long as it stays deactivated, so timely, accurate submission — with the details, PAN and proofs matching MCA's records — matters.

A prescribed government fee applies for a fresh DIN application (via Form DIR-3 for an existing company, or bundled into SPICe+ for a new incorporation). This is a separate, one-time step distinct from Form DIR-3-KYC-Web, which is for a DIN already allotted — KYC compliance, changes of particulars and reactivation. Current fee amounts should always be confirmed at the time of application.

Yes. For clients on PNPC's annual MCA compliance retainer, DIR-3 KYC for every director is tracked alongside AOC-4, MGT-7, ADT-1, and other statutory deadlines as a single integrated compliance calendar — including each director's confirmed KYC due date and any change-of-particulars window that a director reports to us — not managed as a separate, easily-overlooked task.

The Companies Act treats a false statement in the form or certificate seriously — the form itself cites liability under section 448 of the Act and the Bharatiya Nyaya Sanhita, 2023. The DIN holder signs the declaration and a practising professional signs the certificate, so both should be satisfied that every particular is correct before submission. If you discover an error after filing, speak to PNPC promptly so it can be assessed and corrected rather than left on the record.

Rule 12A(1) applies to every individual who holds a DIN as on 31 March of a financial year, and the amendment does not set out exemptions. Whether a DIN that has been surrendered, cancelled or deactivated still carries the obligation depends on its status on MCA master data, which PNPC checks before advising. DIR-5 surrender is available only in limited circumstances; PNPC confirms eligibility before advising it.

The form requires OTP verification of both your existing mobile number and email ID and, where you are updating them, the new ones. OTP delivery issues are usually linked to mobile network delays, a number that has changed carriers, DND (Do Not Disturb) settings blocking transactional SMS, or, for international numbers, carrier-side filtering. Retrying after a short interval resolves most cases; a persistent failure needs to be escalated and resolved early rather than at the last hour — particularly if a thirty-day change window is running.

Aadhaar is one of the accepted residential proofs on the form, alongside a voter identity card, passport, driving licence, bank statement or utility bill. Separately, the income tax PAN is verified on the form. The one-time passwords are sent to the mobile number and email ID given on the form.

Yes. PNPC's Dubai office coordinates directly with UAE-resident directors for document collection and OTP timing across time zones, working alongside our India-side filing team so the director deals with one coordinated process rather than two disconnected ones. Where a foreign address proof or passport needs any notarisation or apostille for the filing, we confirm that requirement against the live form rather than assume it.

PNPC charges a fixed, agreed fee for DIR-3 KYC work, confirmed in writing before work begins — the fee depends on whether the engagement is a routine KYC intimation, a change-of-particulars filing or a reactivation, and whether it includes query resolution. Clients on our annual compliance retainer typically have DIR-3 KYC tracking included as part of the broader package rather than billed separately. This is separate from the government fee, which is confirmed at the time of filing.

A director confident of the mechanics can prepare the filing, though the form carries a practising professional's certificate as well as the director's own digitally signed declaration. Where PNPC adds value is in tracking the obligation proactively across every company and every director we serve — a three-year KYC date and a thirty-day change window are both easy to lose track of — and in correctly diagnosing and resolving the more complex cases: change-of-particulars filings, foreign-director coordination, and reactivation after deactivation, particularly when disqualification issues are entangled with a simple KYC lapse.

Confirmation of your KYC due date under the three-year rule and what Form DIR-3-KYC-Web is to be filed for, document collection and PAN/address reconciliation, OTP coordination with the director, the professional's certificate by PNPC's practising CA where the form requires it, submission and confirmation of the DIN's status on MCA's master data, and — where a DIN has already been deactivated — diagnosis of the cause and a reactivation filing, plus a check of filings that may have stalled at companies PNPC serves, with any others flagged to the director.

Yes. The form is filed per individual DIN holder, so each director with a deactivated DIN needs their own separate filing, even though both may be directors of the same company. Confirm the fee position for each DIN at the time of filing under the MCA fee rules.

While your DIN is deactivated, you cannot be validly appointed as a director at a new company using that DIN, since the appointment filing itself requires a digitally signed form and an active DIN. Once the reactivation is filed and the DIN restored, this restriction lifts and normal appointment filings can proceed.

For clients engaged on our compliance tracking or annual retainer services, PNPC proactively tracks each relevant director's confirmed KYC due date and initiates the filing process without waiting to be asked. Because the KYC cycle is now three years, a reminder can easily be forgotten between filings, so we treat it as a tracked item rather than a service the client needs to remember to request. A change in a director's mobile number, email or address still needs to be reported to us promptly, since that filing is due within thirty days of the change.