DPT-3 for FY 2025-26: New 31 July Deadline & Who Must File

If a director, a sister company, or a bank has lent you money, you almost certainly have to file DPT-3 — even though none of it is a "deposit."

Due date, FY 2025-26: ~~30 June 2026~~ → 31 July 2026

A Pune SaaS company has never taken a rupee of public deposit. To bridge a tight payroll month, the founder-director put in ₹18 lakh of her own money. The books call it an unsecured director's loan and move on. That single entry is exactly what DPT-3 exists to capture — and the company secretary who waves it off as "we have no deposits" has just started a penalty clock.

That mistake is the most common reason companies miss this filing, year after year. The fix takes an afternoon. The penalty for ignoring it compounds by the day. Here is everything that actually matters for FY 2025-26 — what changed this month, who files, what you report, and what it costs to get wrong.

BOTTOM LINE

• Who: Every company except government, banking, RBI-registered NBFC and NHB-registered housing-finance companies — including a private limited with only a director's loan outstanding.
• By when: 31 July 2026 for FY 2025-26 (extended from 30 June), reporting the position as on 31 March 2026.
• Miss it: Additional fee of 2×–12× the normal fee, plus up to ₹5,000 and ₹500/day on the company and every officer in default.

What is DPT-3, in one minute?

Governs this section: Rule 16, Companies (Acceptance of Deposits) Rules, 2014

DPT-3 is an annual return where a company tells the Registrar of Companies how much money it is holding that came in as a loan, an advance, or a deposit — and is still outstanding on 31 March.

The name is misleading. It reads as a "return of deposits," so founders assume it only matters if they ran a chit-fund-style deposit scheme. The 2019 amendment to the Companies (Acceptance of Deposits) Rules widened it far beyond that. Today the form has two jobs: report any actual deposits, and report the long list of borrowings the law specifically says are not deposits but still wants on record.

That second bucket is where almost every private company lives. You probably have nothing in the first.

Didn't the deadline just change?

Governs this section: MCA General Circular No. 02/2026, dated 19 June 2026

Yes — and most companies haven't caught up. The usual deadline is 30 June. For FY 2025-26, the MCA pushed it to 31 July 2026 with no additional fees, through General Circular No. 02/2026 dated 19 June 2026.

The reason is unusually concrete: a fire at the MCA Data Centre on 5 June 2026 forced restoration work on the MCA21 V3 portal, and the relaxation buys companies a month while the system stabilises.

DEADLINE — File by 31 July 2026.

The extension only waives the additional fee — it is not a free pass to wait until the last evening. The V3 portal is still recovering, and it will time out on you at least once. Prepare the data now, and save the draft before you upload anything large.

I never took deposits — do I still file?

The expensive assumption

Almost certainly, yes. This is the single point worth being blunt about: "no public deposits" does not mean "no DPT-3." The form captures money the Act calls "not a deposit" — and that category is enormous.

If any of these were outstanding on 31 March 2026, you file:

• a loan from a director or a relative of a director;
• a loan from a holding, subsidiary or associate company;
• any inter-corporate loan from another company;
• a bank or NBFC term loan, working-capital facility or overdraft;
• a convertible note above ₹25 lakh (subject to conditions);
• customer advances that have been sitting for more than 365 days.

The mental model that actually works is a flowchart, not a definition:

[DIAGRAM 1 — Decision tree: "Do I need to file DPT-3?"]

Build a simple yes/no flow from this logic:

• Are you a company under the Companies Act, 2013? → if no, stop.
• Are you a govt / banking / RBI-NBFC / NHB housing-finance company? → if yes → EXEMPT, no DPT-3.
• Any loan, deposit or advance outstanding on 31 March 2026? → if no → file a NIL return (best practice). → if yes → FILE DPT-3 by 31 July 2026, even if it's only a director loan.

Caption: The only test that matters: outstanding ≠ exempt from reporting.

Who is genuinely exempt?

Governs this section: Rule 16A(3); proviso to Section 73(1)

The exemption list is short and specific. If you are not on it, you file.

PRACTITIONER'S NOTE

Insurance companies are the grey area. There is no explicit line for them in the rule, but because they are regulated by IRDAI rather than the RBI, professional practice and MCA helpdesk responses generally treat them as outside DPT-3. If you advise an insurer, document the basis rather than assuming it.

What exactly do I report?

Governs this section: Rule 2(1)(c) — the classification test

Three buckets. Get an amount into the right one and the rest of the form is data entry.

The middle row is the one that trips people. Those amounts are exempt from the deposit rules, not from reporting. When you file them, you cite the specific sub-clause of Rule 2(1)(c) that exempts each — for a director's loan in a private company, that's Rule 2(1)(c)(viii), and it must be backed by the director's written declaration that the money is her own, not on-lent borrowed funds.

Do I need an auditor's certificate?

Governs this section: form help-kit — return-type radio buttons 2 & 4

It depends on which return type you pick on the form — and this is genuinely the most misunderstood part:

So the typical private company reporting nothing but a director's loan and a bank facility does not need an auditor's certificate. When one is needed, there is no prescribed format — the ICAI has published an illustrative one auditors generally adapt. And note: the form itself can be signed by a director, manager, CEO, CFO or company secretary; it does not require separate certification by a practising professional.

What does it cost if I miss it?

Governs this section: Rule 21; Fees Rules; Section 73

There are three different cost layers, and conflating them is how blogs scare people with the wrong number.

Layer one — the late fee. File after the deadline and the MCA stacks an additional fee on the normal filing fee, scaled to how late you are:

The "normal fee" itself is small and based on share capital — from ₹200 (capital under ₹1 lakh or no share capital) up to ₹600 (capital of ₹1 crore or more).

Layer two — the Rule 21 penalty. This is the one that bites for plain non-filing:

PENALTY · Rule 21

The company and every officer in default can be fined up to ₹5,000, and where the default continues, a further ₹500 for every day it runs. It attaches to the people who signed, not just the entity.

Layer three — Section 73, the heavy one. The figures you'll see quoted — up to ₹10 crore and imprisonment up to 7 years — are real, but they apply to actually accepting deposits in breach of the law, not to a late DPT-3 on exempt loans. Don't let a vendor frame a missed return as a ₹10 crore event. Do take it seriously if your company has genuinely been taking deposits it shouldn't.

A worked example with the numbers

Mini-case — the Pune SaaS company: one director loan, one bank facility, zero deposits

Back to our company. As on 31 March 2026, its books show:

The director's loan goes in citing Rule 2(1)(c)(viii); the bank facility under Rule 2(1)(c)(iii). The ₹6 lakh customer advance is under 365 days old, so it stays out — for now. Total deposits: ₹0. So this is not a NIL return — there's ₹58 lakh to report — but it needs no auditor's certificate, because it's a return of exempted receipts only.

Now suppose they'd believed "no deposits, no filing" and surfaced it 70 days late. Normal fee (capital ₹10 lakh) is ₹400; the 60–90-day slab makes the additional fee 6×, i.e. ₹2,400 on top — plus exposure to the Rule 21 fine on the company and the officers who let it slip. A few thousand rupees and a director's name on a default list, to skip an afternoon's work.

Common mistakes

The five mistakes that cause late filings:

1. "No deposits, so it doesn't apply." The reason most late filings happen. Exempted loans are still reportable.
2. Forgetting the director's declaration. A private company's director loan needs a written declaration that the funds are the director's own — and a note in the Board's report. No declaration, shaky filing.
3. Filing the wrong return type. Picking "Return of Deposits" when you only have exempted receipts triggers a needless auditor's-certificate requirement — and a possible query.
4. Skipping the NIL return. Not strictly mandatory when nothing is outstanding, but filing it keeps your compliance trail clean and pre-empts ROC scrutiny. File it.
5. Treating revision as easy. DPT-3 can't simply be re-filed. Fixing an error means approaching the ROC to mark the original defective. Get the numbers right the first time.

Before-you-file checklist

1. Pull the trial balance as on 31 March 2026 and list every loan, deposit and advance outstanding.
2. Classify each amount: deposit, exempted-but-reportable, or out of scope — and note the Rule 2(1)(c) sub-clause for the exempted ones.
3. Collect the director's declaration for any director/relative loan in a private company.
4. Confirm your net worth figure from the latest audited balance sheet.
5. Pick the correct return type (most companies: exempted receipts only — no auditor's certificate).
6. File on the MCA21 V3 portal and pay the fee. Save the SRN and the challan.
7. Don't wait for 31 July. The portal is still recovering from the June outage.

FAQ

Is a NIL DPT-3 return mandatory? Not strictly, when nothing is outstanding on 31 March. But filing a NIL return is strong practice — it documents that you considered the obligation and keeps your ROC record clean. Most company secretaries file it as a default.

Does a One Person Company (OPC) have to file DPT-3? Yes. OPCs, private limited, public limited and Section 8 companies all fall within DPT-3. Only the four exempt categories — government, banking, RBI-registered NBFC, NHB housing-finance — are out.

Are bank loans really reportable, even though they're obviously not deposits? Yes. Loans from banks, NBFCs and financial institutions are "exempted deposits" under Rule 2(1)(c)(iii) — exempt from the deposit rules, but still reported in DPT-3.

What period does the FY 2025-26 return cover? It reports amounts outstanding as on 31 March 2026. The filing window runs to 31 July 2026 for this year (extended from 30 June via MCA General Circular 02/2026).

Can I revise a DPT-3 after filing? Not directly. If you find an error, you generally have to ask the Registrar of Companies to treat the original filing as defective before a corrected return is accepted — so accuracy on the first attempt matters.

Primary sources

• MCA General Circular No. 02/2026 dated 19 June 2026 — DPT-3 fee relaxation (mca.gov.in → Circulars; link the exact PDF)
• Rule 16 & Rule 16A, Companies (Acceptance of Deposits) Rules, 2014
• Rule 2(1)(c) — amounts not considered deposits
• Section 73, Companies Act, 2013 & Rule 21 — penalties

Disclaimer: This article is general information on a fast-changing area of company law, current at the time of writing. It is not legal or professional advice for any specific company. Verify the position against the live MCA notification and consult your company secretary or auditor before filing.