MCA Shifts Annual Filing to Triennial Cycle (Effective 2026)
Introduction
The Ministry of Corporate Affairs (MCA) vide Notification No. G.S.R. 943(E) dated 31st December 2025, notified the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025. As per the said notification, effective from 31st March 2026, the compliance requirement for filing Form DIR-3 KYC has been fundamentally amended.
The annual filing requirement has been replaced with a triennial (once in 3 years) filing regime.
Key Amendments at a Glance
- Filing Frequency Changed:
As per amended Rule 12A, every individual holding a DIN as on 31st March of a Financial Year shall now be required to file Form DIR-3 KYC-Web once in every 3rd consecutive Financial Year. The previous requirement of annual filing stands withdrawn.
- Single Form Regime:
The erstwhile dual-form system comprising Form DIR-3 KYC (e-form) and DIR-3 KYC-Web has been abolished. With effect from 31st March 2026, there shall be only one form, namely Form DIR-3 KYC-Web.
- Revised Due Dates:
| Category of DIN Holder | Last KYC Filed | Next Due Date |
| DIN allotted on or before 31st March 2025 | FY 2024-25 | 30th June 2028 |
| DIN allotted during FY 2025-26 | FY 2025-26 | 30th June 2029 |
No routine filing is required for FY 2026-27 and FY 2027-28 for existing DIN holders.
- Mandatory 30-Day Update – A Critical Change:
Notwithstanding the 3-year cycle, MCA has introduced a mandatory event-based filing. In case of any change in Personal Mobile Number, Personal Email ID or Residential Address, the DIN holder is mandatorily required to file Form DIR-3 KYC-Web within 30 days of such change.
Note: Such mid-cycle update does not reset the 3-year cycle. The cycle shall continue to be reckoned from the year of DIN allotment.
- Fees and Certification:
– Routine Triennial Filing (within due date): No Government Fee. OTP based authentication only. No certification by a professional required.
– Update Filing (on change of details): Fees as prescribed under Companies (Registration Offices and Fees) Rules, 2014 shall be applicable. DSC of Director and certification by a Practising Professional (CS/CA/CMA) is mandatory.
- Consequences of Non-Compliance:
In case of failure to file within the due date or failure to update changes within 30 days, the DIN shall be marked as “Deactivated due to non-filing of DIR-3 KYC”.
Consequences:
– DIN cannot be used for filing any form with MCA (including AOC-4, MGT-7, DIR-12).
– Reactivation is possible only after filing Form DIR-3 KYC-Web along with a penalty of Rs. 5,000/-.
Conclusion
While the amendment provides significant relief by reducing the compliance burden, the 30-day update rule has made the compliance more stringent. All DIN holders and Companies are advised to maintain a proper tracker for their DINs and ensure timely reporting of any change in KYC details.
Team CSPKINDIA
M/s Praveen K & Associates |Company Secretaries|
Email Id: praveenkandassociates@gmail.com
Contact: +91 8800343499
Legal Reference/Sources:
Notification: MCA Notification No. G.S.R. 943(E) dated 31.12.2025 [Companies (Appointment and Qualification of Directors) Amendment Rules, 2025] – Effective from 31.03.2026.
Relevant Rule: Amended Rule 12A of Companies (Appointment and Qualification of Directors) Rules, 2014 regarding DIR-3 KYC.
Leave a Reply