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ComplianceProducer Company

Compliance Calendar for Producer Company

Joel Dsouza
Updated:
7 min read
Compliance Calendar for Producer Company

The compliance calendar for producer Companies outlines the key statutory obligations under the Companies Act, 2013. These include Board meetings, the AGM, statutory audit, ROC filings such as AOC-4 and MGT-7, and applicable tax and event-based filings.

Producer Companies now operate under Chapter XXIA (Sections 378A–378ZU) of the Companies Act, 2013. Missing a deadline can lead to ₹100 per day late fees, penalties, and other legal consequences. A well-maintained compliance calendar helps track each requirement and complete it on time throughout the financial year.

Key Takeaways

  • Farmer Producer Company Registration follows Chapter XXIA (Sections 378A–378ZU) of the Companies Act, 2013, rather than the earlier Part IXA of the Companies Act, 1956.
  • Key ROC filings include Form AOC-4 within 30 days of the AGM, MGT-7 within 60 days of the AGM, DIR-3 KYC by 30 September, and DPT-3 by 30 June.
  • MSME-1 is due by 31 October for April–September and 30 April for October–March, while event-based forms such as BEN-2 generally fall due within 30 days of the relevant trigger.
  • A Producer Company must hold at least four Board meetings each year, with no gap of more than three months, hold an AGM, and complete its annual statutory audit.
  • It must also file its applicable income tax return, with ITR-6 generally due by 31 October where audit requirements apply. Eligible Producer Companies may also claim the Section 80PA deduction for specified activities.
  • Missed deadlines can result in ₹100 per day late fees, statutory penalties, and potential director disqualification, making timely compliance tracking essential.

Types of Producer Company Compliances

A Producer Company’s compliance calendar covers four main areas: ROC filings, periodic and event-based filings, meetings, and tax and audit requirements. Each category has its own filing frequency and deadline.

1. Annual ROC Compliances

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

  • AOC-4: File the financial statements within 30 days of the AGM.
  • MGT-7: File the annual return within 60 days of the AGM.
  • ADT-1: File the auditor appointment within 15 days of the AGM.
  • DIR-3 KYC: Complete director KYC by 30 September.

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 loans by 30 June.
  • MSME-1: File the half-yearly return for outstanding MSME dues by 31 October and 30 April.
  • MBP-1: Directors must disclose their interests at the first Board meeting of the financial year.
  • DIR-8: Directors must submit their disclosure of non-disqualification at the first Board meeting.
  • BEN-2: Report significant beneficial ownership within 30 days of receiving Form BEN-1, where applicable.

3. Board and General Meeting Compliances

Regular meetings form a core part of Producer Company governance and must follow the prescribed timelines:

  • Board meetings: Hold at least four meetings each year, with no gap of more than three months between two meetings, as required under Section 378ZB.
  • Annual General Meeting: Hold the AGM under Section 378ZA. Hold the first AGM within 90 days of incorporation and maintain the prescribed interval between subsequent AGMs.

4. Tax and Audit Compliances

Along with corporate filings, a Producer Company must complete its annual audit and applicable tax obligations:

  • Statutory audit: Complete the mandatory annual audit of the company’s financial statements.
  • Income Tax Return (ITR-6): File ITR by 31 October if the company requires a tax audit. Eligible Producer Companies may claim the Section 80PA deduction for specified activities.

Producer Company Compliance Calendar for FY 2026–27

The table below maps the key Producer Company compliances to their expected deadlines for FY 2026–27. 

Due DateComplianceForm / Filing
30 Apr 2026MSME dues return for Oct 2025–Mar 2026MSME-1
30 Apr 2026TDS payment for March 2026Challan
30 May 2026Q4 TDS return for FY 2025–2624Q / 26Q
First Board meetingDirectors’ interest and non-disqualification disclosuresMBP-1 / DIR-8
By Jun 2026First Board meeting of FY 2026–27
15 Jun 2026First advance-tax instalmentChallan
30 Jun 2026Return of deposits and specified outstanding amountsDPT-3
31 Jul 2026Q1 TDS return24Q / 26Q
By Sep 2026Second Board meeting
15 Sep 2026Second advance-tax instalmentChallan
30 Sep 2026Tax audit reportForm 3CA/3CB-3CD
30 Sep 2026Annual General Meeting
30 Sep 2026Director KYCDIR-3 KYC
Within 15 days of AGMAuditor appointment filingADT-1
Within 30 days of AGMFinancial statements filingAOC-4
31 Oct 2026Income tax returnITR-6
31 Oct 2026Q2 TDS return24Q / 26Q
31 Oct 2026MSME dues return for Apr–Sep 2026MSME-1
Within 60 days of AGMAnnual returnMGT-7
15 Dec 2026Third advance-tax instalmentChallan
31 Dec 2026GST annual returnGSTR-9
By Dec 2026Third Board meeting
31 Jan 2027Q3 TDS return24Q / 26Q
By Mar 2027Fourth Board meeting
15 Mar 2027Fourth advance-tax instalmentChallan
30 Apr 2027MSME dues return for Oct 2026–Mar 2027MSME-1
Event-basedBeneficial ownership, director changes, allotments, resolutions, or capital changesBEN-2, DIR-12, PAS-3, MGT-14, SH-7

Note: AGM-linked filings depend on the actual AGM date. The deadlines above assume an AGM on 30 September 2026 and move earlier if the company holds the AGM sooner.

Penalties for Missing Producer Company Compliance Deadlines

Missing Producer Company compliance deadlines can lead to consequences, such as:

  • Late filing of ROC forms: Forms such as AOC-4, MGT-7, ADT-1, and DPT-3 attract an additional fee of ₹100 per day per form, with no upper limit. This fee applies from the due date until the company files the form, over and above the normal filing fee.
  • MGT-7 default under Section 92(5): The company can face a penalty of ₹10,000 plus ₹100 per day of continuing default, capped at ₹2 lakh. Each officer in default can face the same calculation, capped at ₹50,000.
  • AOC-4 default under Section 137(3): The company can incur ₹10,000 plus ₹100 per day for continuing default, capped at ₹2 lakh. The responsible officer or directors can face a penalty up to ₹50,000.
  • Director disqualification under Section 164(2): Failing to file financial statements or annual returns for three consecutive financial years can disqualify the company’s directors for five years and deactivate their DINs.
  • Company strike-off under Section 248: Continued non-compliance can lead the ROC to initiate strike-off proceedings and remove the company’s name from the register, subject to the applicable legal process.
  • Board meeting default under Section 378ZB: A Producer Company must hold at least four Board meetings each year, with no gap exceeding three months. Failure to meet these requirements can expose the company and responsible directors to penalties.

Why a Compliance Calendar Matters for a Producer Company?

Here is what a compliance calendar does for a Producer Company:

  • Keeps AGM filings on track: AOC-4, MGT-7, and ADT-1 follow the AGM date, so timely AGM completion keeps these filings on schedule.
  • Tracks event-based filings: DIR-12, PAS-3, MGT-14, SH-7, and BEN-2 arise after specific events, so a tracker helps flag them promptly.
  • Supports loans and funding: Banks, NABARD, and grant agencies may review statutory and tax records before approving finance.
  • Builds member confidence: Timely audits, financial reports, and AGMs keep producer members informed about company affairs.
  • Manages overlapping deadlines: A calendar helps coordinate DIR-3 KYC, ADT-1, AOC-4, ITR-6, and MGT-7 deadlines between September and November.