Annual Report Deadlines in India: AGM, Dispatch, Hosting, ROC Filing

India's annual report deadlines tend to sit in compliance calendars as four separate dates: the annual general meeting, dispatch to shareholders, website and exchange hosting, and the Registrar of Companies filings. They behave as one chain. Every date hangs off a single fixed point, the AGM date. Move it and the dispatch date moves back with it while the filing dates move forward.

The FY 2025-26 AGM season closed on 30 September 2026. Companies that met on or near the last day are now inside the post-AGM filing window, and the FY 2026-27 calendar is already worth drafting. Two things in older calendars need correcting before anyone copies them across. The LODR's own 21-day dispatch rule no longer exists, and electronic dispatch stopped being a year-to-year SEBI relaxation in December 2024.

Filings due now for the FY 2025-26 season

Each post-AGM clock runs from the date of the AGM, not from the financial year-end. For a company that held its AGM on 30 September 2026:

An AGM held earlier pulls these dates forward day for day. A company that met on 12 September 2026, for instance, had until 12 October for AOC-4 and has until 11 November for MGT-7. MGT-7 for a 30 September AGM lands on a Sunday, and the safe course is to treat the preceding Friday as the working deadline instead of relying on weekend portal uptime.

Where no AGM was held, Section 137 still requires AOC-4 within 30 days of the last date by which the AGM should have been held, along with a statement of the reasons (TaxGuru). If the meeting was missed altogether, the options are narrower; our note on missing the 30 September AGM deadline covers them.

MGT-15 is the form smaller listed companies most often forget, since there's no unlisted-company equivalent to act as a reminder.

The AGM deadline for FY 2026-27

An annual general meeting (AGM) is the meeting at which members adopt the accounts and the annual report is laid before them.

Section 96 of the Companies Act, 2013 requires a company's first AGM within nine months of the close of its first financial year and every later AGM within six months of year-end, with no more than fifteen months between two AGMs. For a 31 March year-end, FY 2026-27 AGMs must be held by 30 September 2027. The ROC can extend the time for any AGM other than the first by up to three months "for any special reason", though that relief is discretionary and shouldn't go into a plan.

Listed entities in the top 100 by market capitalisation get less time. Regulation 44(5) of the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 ('SEBI LODR') requires them to hold the AGM within five months of year-end, which for FY 2026-27 means by 31 August 2027. Regulation 44(6) adds a one-way live webcast of the proceedings.

Membership of the top 100 is no longer fixed by a 31 March snapshot. Regulation 3(2), as it now stands, has the exchanges rank listed entities each year on average market capitalisation between 1 July and 31 December, and newly applicable provisions bite from the following 1 April. The list the exchanges draw up at 31 December 2026 is therefore the one to watch for the August 2027 deadline.

Twenty-one clear days, now from the Companies Act alone

Section 101 requires at least 21 clear days' notice of a general meeting, and Section 136 requires the financial statements, board's report and auditor's report to go to every member, debenture trustee and other entitled person at least 21 clear days before the AGM. Clear days leave out both the day of sending and the day of the meeting.

Until December 2024, Regulation 36(2) of SEBI LODR set a parallel 21-day rule for listed entities. The SEBI (LODR) (Third Amendment) Regulations, 2024 omitted it with effect from 13 December 2024 (consolidated LODR, amended to 14 July 2026). The arithmetic is unchanged. The legal hook for it is now the Companies Act only, and calendars or board notes that still cite Regulation 36(2) should be updated.

Counting backwards for FY 2026-27:

These dates assume electronic dispatch. Where any copies go by post, Rule 35 of the Companies (Management and Administration) Rules, 2014 treats a meeting notice as served 48 hours after posting, so physical dispatch needs a couple of extra days. A board-approved, auditor-signed report has to be ready before these dates, which is why the AGM date should be fixed before the audit timetable instead of after it. For what has to be inside the document, see our annual report contents checklist.

Website and exchange hosting ride on the dispatch date

Regulation 34(1)(a) of SEBI LODR requires a listed entity to submit to the stock exchanges, and publish on its website, the annual report sent to shareholders together with the AGM notice, on or before the day dispatch commences. The words "on or before" replaced "not later than the day of" in the same December 2024 amendment, which makes the point plainer: hosting can come early, never late.

Regulation 34(1)(b) covers late changes. If the annual report is revised after dispatch, the revised copy goes to the exchanges and the website, with details of and reasons for the changes, within 48 hours after the AGM.

In practice: make the exchange upload and website hosting the same calendar event as dispatch, owned by the same person. Teams that print and courier first and upload days later leave a stretch in which shareholders hold a document the market can't see.

Where a company also publishes an HTML edition, it normally follows the PDF; we've costed that exercise in our guide to digital annual reports in India.

Electronic dispatch is now written into LODR

For several years, sending annual reports only by email depended on SEBI circulars renewed season by season, each tracking an MCA circular. That changed with the Third Amendment of 2024. Regulation 36(1), effective 13 December 2024, requires a listed entity to send the annual report:

• as a soft copy of the full report to shareholders who've registered an email address with the company or a depository;
• as a letter giving the web-link, including the exact path, to the full annual report, for shareholders who haven't registered an email;
• as a hard copy of the full report to shareholders who ask for one.

The letter in the second limb replaced the old "hard copy of statement containing the salient features" of the Section 136 documents. A shareholder without email therefore gets a short letter pointing to the report online, and a printed report only on request.

Regulation 58 now follows the same model for holders of listed non-convertible securities. The SEBI (LODR) (Fifth Amendment) Regulations, 2025, effective 19 November 2025, replaced the salient-features statement with a web-link letter, which may also carry a static QR code, and inserted Regulation 58(1A). That sub-regulation ties dispatch to the Section 136 timelines, or to the entity's own governing statute, and where no statutory timeline exists, to the date the documents go to shareholders or to government.

The Companies Act side runs through the MCA. General Circular No. 03/2025, dated 22 September 2025, allows companies to hold AGMs through video conferencing or other audio-visual means "till further orders", in line with paragraphs 3 and 4 of General Circular 20/2020, and continues the parallel EGM and postal-ballot framework (MCA). It also states that it doesn't extend the statutory time for holding AGMs. FY 2025-26 AGM notices filed through 2026 relied on this circular, with emailed annual reports and printed copies on written request. LODR's Regulation 44(4) proviso, added in the same December 2024 amendment, removes the proxy-form requirement for meetings held only in electronic mode.

In practice: the yearly "has the relaxation been extended?" check can come off the listed-company checklist. A shorter check replaces it: confirm that General Circular 03/2025 hasn't been withdrawn or superseded before fixing a virtual AGM, and that the web-link letter for non-email holders is drafted and printed in time.

Annual report and annual return are different documents

The two terms get swapped in boardroom conversation often enough to be worth separating.

The annual report is the shareholder document: financial statements, board's report, auditor's report, corporate governance report and, where applicable, the BRSR. It goes to members under Section 136 and reaches the ROC through AOC-4. Whether the BRSR belongs in it is a separate test, covered in our note on BRSR applicability for FY 2025-26.

The annual return, filed in MGT-7 or MGT-7A under Section 92, is a snapshot of shareholding, indebtedness, management and other particulars as at year-end (TaxGuru). Form MGT-7 was substituted in a revised format during 2025, so it's worth comparing this year's draft with the form currently live on the MCA portal before the November deadline instead of reusing a template from two seasons ago.

Why the top 100 run on a tighter clock

The SEBI overlay adds to the Companies Act timeline and doesn't replace any of it. A top-100 company still meets Sections 101, 136, 137, 92 and 121, all compressed inside a five-month AGM window and with a webcast that smaller listed entities don't owe.

The squeeze shows up at dispatch. A 9 August dispatch date means the audited accounts, board's report and BRSR need to be final in late July, roughly a month ahead of a company working to 30 September. Companies near the threshold should track their average market capitalisation through the second half of 2026, because crossing into the top 100 moves the AGM deadline, the dispatch date and the webcast obligation in one step.

Building the FY 2026-27 calendar

Start from the AGM date the board is likely to choose and count back 21 clear days to fix dispatch, then add the exchange upload and website hosting to that same day. If any shareholders still receive paper, allow for the 48-hour deemed-service rule.

Then count forward from the AGM: 30 days for AOC-4 and MGT-15, 60 for MGT-7. Put weekday checks against both, since a 30 September AGM sends MGT-7 into a Sunday.

Keep the annual report and annual return as separate workstreams even where one team owns both. They answer to different sections and different forms, and they get reviewed by different people.

Teams that run the calendar as a single mechanism, with one owner for the AGM date and every other date hanging off it, tend to finish without the September scramble. For the month-by-month plan, see our guide on how to start preparing an annual report.