DPT-3 & MSME-1: The Two ROC Filings Every Company Quietly Misses

DPT-3 at a glance

• Return of deposits and details of money received that is not a deposit (advances, loans from directors, etc.)
• Filed every year as on 31 March - due 30 June 2026 for FY 2025-26
• One-time DPT-3 at time of acceptance of deposits by eligible companies
• Small companies and eligible private limited companies exempt from the annual return (but must maintain records)
• Certification: signed digitally; no audit requirement for the nil-deposit return

MSME-1 at a glance

• Half-yearly return for dues unpaid beyond 45 days to registered MSME suppliers
• Due 30 April and 31 October
• Filed under MSMED Act 2006 read with Companies Act - track trade payables to Udyam-registered vendors
• Penalty Rs. 1,000 per day per officer in default on the buyer company
• No special certification needed

Why they get missed

Neither form comes with a public reminder like AOC-4 or MGT-7. Directors schedule the AGM, the CS files annual returns - and the DPT-3 window of 1 April - 30 June quietly passes. MSME-1 is only triggered when a vendor's payment crosses 45 days, a fact that many AP teams never report to the compliance desk.

Impact on your company

A missing MSME-1 is a red flag in vendor diligence and blocks fresh ROC filings in some jurisdictions. DPT-3 defaults attract adjudication notices under Section 76A with minimum fines of Rs. 50,000 for the company. Both also leave the 'Active Non-Compliant' tag on the company's MCA profile for third parties to see - lenders check it.

What you should do

• Mark 30 June 2026 (DPT-3) in the compliance calendar now
• Ask your AP team to flag every vendor whose invoice crosses 45 days - that is your MSME-1 trigger
• File MSME-1 within 30 days of the relevant half-year even if your company disputes the dues
• Keep the list of 'money received not being deposits' (advances, security deposits) ready for DPT-3
• Reconcile DPT-3 loan schedules with the balance sheet to avoid mismatch in MCA scrutiny