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Checklist · FPO Formation · 6 min read

FPO annual compliance calendar 2026–27

Min. 4 / yr
Board meetings, ≤120 days apart
30 Sept
AGM deadline (6 months from FY end)
2 filings
AOC-4 + MGT-7/7A after AGM
12 months
April 2026 – March 2027 covered

Note on scope: This calendar is written for FPOs registered as producer companies under Chapter XXIA of the Companies Act, 2013. Section 8 companies follow the same MCA/Income-tax calendar shown here. Cooperative societies instead follow their state Registrar of Cooperative Societies' own filing calendar, which is not covered in this guide.


Why compliance slippage is the #1 FPO killer

More FPOs lose good standing, lender confidence, and scheme eligibility through missed filings than through any single business failure. A produce season can go wrong and recover the next year — a struck-off company, a disqualified director, or a lapsed auditor appointment takes far longer to fix, and can quietly block a loan, a grant disbursement, or a buyer contract at the worst possible moment. Most of these slips are entirely avoidable with a simple calendar the board actually follows. That is what this guide provides — read alongside our Section 8 registration guide and structure comparison guide if you are still finalising your FPO's legal form.


Month-by-month calendar (April 2026 – March 2027)

Month Compliance item
April 2026 Financial year 2026–27 begins (assuming April–March FY). Review previous year's board meeting minutes and statutory registers are up to date.
May 2026 TDS return (24Q/26Q) for Q4 of FY 2025–26 due by 31 May.
June 2026 DPT-3 (return of deposits/exempted borrowings) due by 30 June, for the previous FY.
July 2026 TDS return (24Q/26Q) for Q1 due by 31 July. Board meeting due if gap since the last meeting is approaching 120 days.
August 2026 Finalise audited financial statements for FY 2025–26 in preparation for the AGM. Confirm auditor availability and draft the AGM notice.
September 2026 AGM (by 30 Sept) · DIR-3 KYC for all directors (by 30 Sept) · Tax audit report 3CA/3CB-3CD (by 30 Sept, where applicable)
October 2026 AOC-4 due within 30 days of AGM. ADT-1 (auditor appointment) due within 15 days of the AGM. TDS return for Q2 due by 31 Oct. ITR-6 due by 31 Oct for audit cases.
November 2026 MGT-7/MGT-7A (annual return) due within 60 days of AGM — typically falls in this month if the AGM was held in September.
December 2026 GSTR-9 (annual GST return), if registered, due by 31 December for the previous FY.
January 2027 TDS return for Q3 due by 31 Jan. Review board meeting cadence — ensure a meeting has been held within any rolling 120-day gap.
February 2027 Begin planning for FY 2027–28 — budget, business plan review, and any share allotments should have share certificates issued (within 2 months of allotment).
March 2027 Financial year 2026–27 closes. Ensure at least 4 board meetings were held across the year with no gap exceeding 120 days. Begin closing-of-books preparation.

Monthly/quarterly GST filings (GSTR-1, GSTR-3B), if your FPO is GST-registered, run throughout the year per your assigned filing frequency and are not repeated in every row above.


The recurring items explained

Board meetings. Under current rules, a producer company must hold a minimum of 4 board meetings per year, with the gap between any two consecutive meetings not exceeding 120 days. Spacing these roughly one per quarter is the simplest way to stay compliant without needing to track exact day-counts.

AGM. The Annual General Meeting must be held within 6 months of the financial year end — by 30 September for an April–March FY. A company's very first AGM has a longer window: within 9 months of the end of its first financial year.

AOC-4 and MGT-7/MGT-7A. After the AGM, AOC-4 (filing the financial statements) is due within 30 days, and MGT-7 or MGT-7A (the annual return) is due within 60 days of the AGM.

DIR-3 KYC. Every director with a DIN must complete DIR-3 KYC annually, by 30 September, regardless of whether their details have changed.

DPT-3. This return, covering deposits and certain exempted borrowings, is due by 30 June each year.

ADT-1. When an auditor is appointed or reappointed at the AGM, Form ADT-1 must be filed within 15 days of that AGM.

Income tax and TDS. ITR-6 is due by 31 October for companies subject to audit, with the tax audit report (Form 3CA/3CB and 3CD) due by 30 September where a tax audit applies. TDS returns (Forms 24Q/26Q) are filed quarterly, by 31 July, 31 October, 31 January, and 31 May.

GST. If your FPO is GST-registered, GSTR-1 and GSTR-3B are filed monthly or quarterly depending on turnover and the scheme you're registered under, and the annual return GSTR-9 is due by 31 December.

Registers, minutes, and share certificates. Statutory registers (of members, directors, charges) and minutes books should be updated continuously, not reconstructed at year-end. Share certificates must be issued within 2 months of allotment — a common gap when new farmer-members are onboarded mid-year and certificate issuance is deferred indefinitely.


Penalties and consequences of missing deadlines

Late filing of MCA forms (AOC-4, MGT-7/7A, ADT-1, DPT-3) attracts additional filing fees that scale with the delay, on top of the normal filing fee — under current rules, these are levied per form and accumulate the longer the delay continues. Persistent non-filing can result in the company being flagged as a defaulting company, directors being disqualified from holding directorships in other companies, and in extreme cases the RoC striking the company off the register. A struck-off company cannot operate a bank account normally or enter enforceable contracts, and restoration is a formal (and slow) process through the National Company Law Tribunal.

Missing DIR-3 KYC deactivates a director's DIN until the filing (with a late fee) is completed, which can stall any transaction requiring that director's signature — including bank operations and MCA filings. Missed tax-audit or ITR deadlines attract interest and penalty under the Income-tax Act, and can also affect eligibility for certain scheme benefits that require clean tax compliance as a precondition.


The three most-missed filings

⚠ DIR-3 KYC for directors who "haven't changed anything"

Directors often assume that if their address, phone, or email hasn't changed since last year, no fresh KYC filing is needed. It is an annual requirement regardless of whether details changed. Missing the 30 September deadline deactivates the DIN and can silently block filings that need that director's signature weeks later.

⚠ DPT-3 treated as "not applicable to us"

Boards sometimes assume DPT-3 only applies to companies accepting public deposits. In practice it also covers certain exempted borrowings and loans from directors/members, which many FPOs do carry on their books. Have your CA confirm applicability every year by the 30 June deadline rather than assuming it's a nil filing.

⚠ AGM held late, then AOC-4/MGT-7 timelines miscalculated

Because AOC-4 and MGT-7/MGT-7A deadlines count from the actual AGM date — not from the financial year end — an AGM held late (even within the permitted window) pushes every downstream deadline with it. Boards that use 30 September as a fixed reference point for AOC-4/MGT-7, instead of their own actual AGM date, frequently miscalculate and file late.


Want a compliance partner instead of a spreadsheet?

Mujanti tracks board meeting cadence, MCA filings, and tax deadlines for FPOs across Karnataka, Tamil Nadu, Maharashtra, and Odisha, so your board can focus on the business, not the calendar.

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This calendar reflects standard Companies Act, 2013 and Income-tax Act filing deadlines as commonly applied to producer companies and Section 8 companies, as understood as of July 2026. Exact due dates, late fees, and applicability (for example, tax audit thresholds or GST filing frequency) depend on your FPO's specific turnover, structure, and any government extensions notified during the year. Always verify current deadlines and fee schedules with your company secretary, chartered accountant, or the MCA/Income Tax/GST portals before relying on this calendar.