Compliance Calendar for Producer Company in India

Key Takeaways

• Farmer Producer Company Registration is governed by Chapter XXIA of the Companies Act, 2013, which contains provisions specifically applicable to Producer Companies.
• Key ROC compliances include AOC-4 within 60 days of the AGM under Section 378ZA(10), the annual return under Section 92(4) within 60 days of the AGM, and DPT-3 by 30 June, where applicable. 
• Producer Companies must also file the AGM proceedings, Board’s Report, audited balance sheet, and profit and loss account within 60 days of the AGM under Section 378ZA(10).
• MSME-1 is due by 31 October for the April–September period and 30 April for the October–March period, where the reporting conditions are met. Event-based forms such as BEN-2 are filed within the prescribed period after the relevant trigger.
• A Producer Company must hold at least four Board meetings every year, with no more than three months between two consecutive meetings. It must also hold an AGM and complete its annual statutory audit.
• Producer Companies have additional requirements under Chapter XXIA, including filing AGM proceedings with the Registrar within 60 days and following internal audit, reserve, member-related, and other applicable requirements.
• Income tax return filing, TDS, advance tax, and tax audit requirements apply where applicable. The due dates and return forms depend on the company’s tax and audit requirements. 
• Delayed filings may result in additional filing fees, statutory penalties, interest, or other consequences, depending on the compliance involved. Director disqualification may also arise in cases covered by the Companies Act.

Producer Company Compliance Calendar for FY 2026-27

The compliance calendar for a Producer Company includes ROC filings, tax compliances, Board and general meetings, and periodic and event-based requirements. Some deadlines are fixed, while others depend on the AGM date or a specific event.

Due Date / Timeline	Compliance	Form / Requirement
30 Apr 2026(Passed)	Deposit TDS deducted in March 2026, where applicable. Next: 30 Apr 2027	TDS payment
30 Apr 2026(Passed)	File MSME-1 for the October 2025–March 2026 period, where applicable. Next: 31 Oct 2026	MSME-1
31 May 2026(Passed)	File TDS statement for Q4 of FY 2025-26, where applicable. Next: 31 Jul 2026	Form 138 / Form 140 / Form 144, as applicable
15 Jun 2026(Passed)	First advance-tax instalment for Tax Year 2026-27, where applicable. Next: 15 Sep 2026	Advance tax
30 Jun 2026(Passed)	File statement of outstanding deposits and specified particulars, where applicable. Next: 30 Jun 2027	DPT-3
During the year	Hold at least four Board meetings, with no more than three months between consecutive meetings, subject to applicable provisions.	Section 378V
31 Jul 2026(Passed)	File TDS statement for Q1 of FY 2026-27, where applicable. Next: 31 Oct 2026	Form 138 / Form 140 / Form 144, as applicable
15 Sep 2026(Passed)	Second advance-tax instalment for Tax Year 2026-27, where applicable. Next: 15 Dec 2026	Advance tax
30 Sep 2026	File tax audit report for FY 2025-26, where applicable.	Form 3CA / 3CB and 3CD
31 Oct 2026	File income-tax return for FY 2025-26, where applicable.	ITR for FY 2025-26
31 Oct 2026	File TDS statement for Q2 of FY 2026-27, where applicable.	Form 138 / Form 140 / Form 144, as applicable
31 Oct 2026	File MSME-1 for the April–September 2026 period, where applicable.	MSME-1
15 Dec 2026	Third advance-tax instalment for Tax Year 2026-27, where applicable.	Advance tax
31 Dec 2026	File annual GST return and reconciliation statement, where applicable.	GSTR-9 / GSTR-9C
31 Jan 2027	File TDS statement for Q3 of FY 2026-27, where applicable.	Form 138 / Form 140 / Form 144, as applicable
15 Mar 2027	Final advance-tax instalment for Tax Year 2026-27, where applicable.	Advance tax
30 Apr 2027	Deposit TDS deducted in March 2027, where applicable.	TDS payment
30 Apr 2027	File MSME-1 for the October 2026–March 2027 period, where applicable.	MSME-1
31 May 2027	File TDS statement for Q4 of FY 2026-27, where applicable.	Form 138 / Form 140 / Form 144, as applicable
Within 60 days of AGM	File the financial statements, Board’s Report, auditor’s report, and AGM proceedings required under Section 378ZA(10) with the Registrar.	AOC-4 / Section 378ZA(10)
Within 60 days of AGM	File the applicable annual return.	MGT-7 / applicable annual return
Within 15 days of auditor appointment or reappointment	File notice of auditor appointment or reappointment, where applicable.	ADT-1
By 30 June of the applicable third financial year	Complete director KYC where the director’s triennial KYC filing falls due.	DIR-3 KYC Web
Within 30 days of receipt of the required declaration	File beneficial ownership disclosure, where applicable.	BEN-2
As prescribed / when required	Make director disclosures and maintain required records.	MBP-1 / DIR-8
Event-based	File applicable changes relating to directors, share capital, allotments, resolutions, charges, and other corporate events.	DIR-12 / PAS-3 / SH-7 / MGT-14, etc.
As prescribed in the Articles	Conduct internal audit of accounts by a Chartered Accountant.	Section 378ZF
As applicable	Complete other Producer Company-specific requirements relating to reserves, members, shares, loans, investments, and other Chapter XXIA requirements.	Chapter XXIA

Note: AGM-linked compliances must be calculated from the actual AGM date. A Producer Company must hold its first AGM within 90 days of incorporation. For subsequent AGMs, no more than 15 months should elapse between two consecutive AGMs. The Registrar may permit an extension of up to three months for a subsequent AGM for special reasons. 

Section 378ZA(10) requires a Producer Company to file its financial statements, Board’s Report, auditor’s report, and AGM proceedings with the Registrar within 60 days of the AGM. 

Disclaimer: This calendar is a general reference. The exact compliance list depends on the Producer Company’s turnover, GST registration, employees, transactions, borrowing or deposits, share activity, beneficial ownership, and other applicable conditions.

Compliances Applicable to Producer Companies in India

A Producer Company’s compliance calendar covers annual ROC filings, periodic and event-based filings, meetings, and tax and audit requirements. Some compliances apply every year, while others arise only when a specific event or condition occurs.

1. Annual ROC Compliances

These compliances help keep the Producer Company’s statutory records updated with the Registrar of Companies:

• AOC-4: File the financial statements within 60 days of the AGM.
• Annual Return: File the applicable annual return within 60 days of the AGM.
• Section 378ZA(10): File the AGM proceedings, Board’s Report, and audited financial statements with the Registrar within 60 days of the AGM, along with the applicable filing fees.
• DIR-3 KYC: Complete the applicable director KYC requirement within the prescribed timeline.

2. Periodic and Event-Based Compliances

These compliances apply at specific intervals or when a prescribed event occurs:

• DPT-3: File the return of deposits and specified outstanding amounts by 30 June, where applicable.
• MSME-1: File the half-yearly return for qualifying outstanding dues to micro or small enterprises by 31 October and 30 April, where applicable.
• MBP-1: Directors must disclose their interests at the first Board meeting in which they participate as directors and update the disclosure when required.
• DIR-8: Directors must provide the required disclosure of disqualification and non-disqualification in the prescribed manner.
• BEN-2: File the return of significant beneficial ownership with the Registrar within the prescribed period after receiving Form BEN-1, where applicable.
• ADT-1: File notice of auditor appointment or reappointment with the Registrar within 15 days of the meeting, where applicable. 
• Other Event-Based Forms: Forms such as DIR-12, PAS-3, SH-7, and other applicable forms may be required when there is a change in directors, allotment of shares, alteration of share capital, or another reportable event.

3. Board and General Meeting Compliances

Meetings are an important part of Producer Company governance and must follow the timelines prescribed under Chapter XXIA:

• Board Meetings: Hold at least four Board meetings in every year, with no more than three months between two consecutive meetings, as required under Section 378V.
• First AGM: Hold the first AGM within 90 days of incorporation.
• Subsequent AGMs: No more than 15 months should elapse between two consecutive AGMs. The Registrar may extend an AGM other than the first AGM by up to three months for special reasons.
• AGM Notice: Give at least 14 days’ prior written notice of the general meeting. The notice must be sent to every Member and the auditor.
• AGM Quorum: Unless the Articles provide for a larger number, one-fourth of the total membership constitutes the quorum for an AGM.
• AGM Proceedings: File the proceedings of the AGM, along with the prescribed documents, with the Registrar within 60 days of the AGM under Section 378ZA(10).

4. Tax and Audit Compliances

Along with ROC and corporate compliances, a Producer Company must meet its applicable audit and tax obligations:

• Statutory Audit: Have its financial statements audited annually by a qualified auditor.
• Internal Audit: A Producer Company is required to conduct an internal audit at the intervals and in the manner specified in its Articles, as prescribed under Section 378ZF.
• Income Tax Return: File its applicable income tax return within the prescribed due date. ITR-6 generally applies to Producer Companies, unless the company is required to file another applicable return form.
• Tax Audit: Where tax audit requirements apply, file the applicable tax audit report within the prescribed timeline before the income tax return due date.

5. Producer Company-Specific Ongoing Compliances

A Producer Company must also follow specific requirements under Chapter XXIA of the Companies Act, 2013. These requirements cover management, accounts, audit, reserves, and member-related matters.

• Chief Executive: Every Producer Company must have a full-time Chief Executive appointed by the Board from among persons other than Members. The Chief Executive is an ex-officio director and does not retire by rotation.
• Whole-Time Secretary: A Producer Company with an average annual turnover exceeding ₹5 crore, or such other amount as may be prescribed, in each of 3 consecutive financial years must have a whole-time secretary. The secretary must be a member of the Institute of Company Secretaries of India.
• Books of Account: The Producer Company must maintain proper books of account at its registered office. The books must record the company’s receipts, expenditure, sales, purchases, assets, liabilities, and other prescribed particulars.
• General Reserve: Every Producer Company must maintain a general reserve in every financial year. The manner of maintaining the reserve is subject to Section 378ZI and the company’s Articles.
• Internal Audit: Every Producer Company must have its accounts internally audited by a Chartered Accountant. The Articles of the Company specify the interval and manner of the audit. 
• Auditor’s Additional Reporting: The statutory auditor must report on additional matters under Section 378ZG. These include debts and bad debts, cash and securities, assets and liabilities, transactions contrary to Chapter XXIA, loans to directors, and donations or subscriptions.
• Member and Share Requirements: Chapter XXIA also contains specific requirements relating to member rights, share transfer, bonus shares, patronage bonus, loans to Members, and investments. These requirements apply when the relevant transaction or circumstance arises.

First-Year Compliance Requirements for a Producer Company

A newly incorporated Producer Company may have additional compliance requirements during its first year. The applicable requirements depend on the company’s incorporation date and the events that occur after incorporation.

• First Auditor: The Board must appoint the first statutory auditor within 30 days of registration. If the Board fails to do so, the Members must appoint the auditor within 90 days at an Extraordinary General Meeting.
• Commencement of Business: Where Section 10A applies, the company must file the declaration of commencement of business in Form INC-20A within 180 days of incorporation.
• Share Certificates: The company must issue share certificates within the prescribed period and maintain the required share records.
• Chief Executive: A Producer Company must appoint a full-time Chief Executive as required under Section 378W.
• Registered Office: The company must maintain a registered office and complete the applicable verification and related filings within the prescribed timeline.
• Statutory Registers and Records: The company must maintain the registers, books, minutes, and other records required under the Companies Act, 2013 and Chapter XXIA.

Proposed Changes Under the Corporate Laws (Amendment) Bill, 2026

The Corporate Laws (Amendment) Bill, 2026 proposes changes to several Producer Company requirements under Chapter XXIA of the Companies Act, 2013. The Bill was introduced in the Lok Sabha on 23 March 2026. The Joint Parliamentary Committee submitted its report on 3 August 2026. As of this update, the Bill has not yet become law; confirm its current status before relying on the proposed changes.

The proposed changes include:

• Appointment of Directors: The Bill proposes changes to the election or appointment of directors by members in general meetings and related provisions under Section 378P.
• Annual General Meeting: It proposes changes to the first and subsequent AGM timelines under Section 378ZA.
• Adoption of Articles and Appointment of Directors: It proposes that members adopt the Producer Company’s articles and appoint directors to its Board at the first AGM.
• AGM Quorum: It proposes a quorum of one-fourth of the total membership or 100 members, whichever is less.
• Internal Audit: It proposes mandatory appointment of an internal auditor for a Producer Company with an average annual turnover exceeding ₹5 crore, or another prescribed amount, in each of the three consecutive financial years.
• Penalties: It proposes changes to certain penalties and offences applicable to Producer Companies, including replacing some existing criminal penalties with monetary penalties.

These are proposed changes and are not the current law. Until the amendments are enacted and brought into force, Producer Companies must continue to comply with the existing provisions of Chapter XXIA.

Therefore, the compliance requirements and due dates in this calendar are based on the provisions currently applicable for FY 2026-27.

Penalties for Missing Producer Company Compliance Deadlines

Failure to complete Producer Company compliances within the prescribed time can result in additional fees, penalties, interest, or other statutory consequences. The consequence depends on the specific compliance and the applicable provision.

• Late Annual Return: Failure to file the annual return can attract a penalty under Section 92(5), subject to the limits prescribed under the Act.
• Late Financial Statements: Failure to file financial statements can attract a penalty under Section 137(3), subject to the limits prescribed under the Act.
• Director Disqualification: Section 164(2) may result in disqualification where a company fails to file its financial statements or annual returns for 3 consecutive financial years, subject to the applicable conditions.
• Board Meeting Notice: Under Section 378V(3), the Chief Executive may be liable to a penalty of ₹5,000 for failure to give the required notice of a Board meeting.
• Whole-Time Secretary: Under Section 378X, a Producer Company that is required to appoint a whole-time secretary but fails to do so may face a penalty of ₹100 for every day of default, subject to a maximum of ₹1 lakh.
• General Meeting: Section 378ZM provides penalties for specified contraventions, including failure by a director or officer to convene an annual general meeting or other general meeting.
• Strike-Off Risk: Persistent non-compliance may also contribute to action for removal of a company’s name from the Register of Companies under Section 248, where the statutory conditions are met.
• AGM Proceedings: Failure to comply with the filing requirement under Section 378ZA(10) may attract the applicable statutory consequences under the Companies Act, 2013. The specific consequence depends on the nature of the default and the provision applicable to the contravention.

Why Producer Company Compliance Matters?

Regular compliance helps a Producer Company maintain its legal status and meet its obligations under the Companies Act, 2013, and other applicable laws.

• Maintains legal compliance: Timely ROC filings, meetings, audits, and statutory records help the company meet its legal obligations.
• Protects directors and officers: Timely compliance reduces the risk of penalties and other consequences for the company and persons responsible for defaults.
• Supports access to finance: Updated financial statements and statutory records can help when the company applies for loans, funding, or other financial support.
• Builds member confidence: Proper records, AGM proceedings, and financial reporting promote transparency among members.
• Tracks Producer Company requirements: Chapter XXIA includes additional requirements relating to members, reserves, internal audit, Board functioning, and other matters.
• Avoids missed deadlines: A compliance calendar helps the company track fixed-date, AGM-linked, and event-based filings throughout the year.

Keeping track of AGM timelines, ROC filings, audits, and other Producer Company compliances can be time-consuming. With professional support from RegisterKaro, you can manage applicable compliances and complete required filings within the prescribed timelines. Contact us today for professional assistance with Producer Company compliance.