/ ROC Catch-up Alert · Updated 2026-10-22

DIR-3 KYC Catch-up November-December 2026, deactivated DINs fixed before year-end.

Directors who missed the DIR-3 KYC deadline (30 September 2026) have deactivated DINs - which blocks all MCA eForm filings. Year-end AOC-4 + MGT-7 + DPT-3 + PAS-6 cannot be filed without active DIN. Catch-up filing with INR 5,000 late fee reactivates DIN within 24-72 hours. Here's the November-December 2026 catch-up alert.

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Written by CA Durgesh Chavda

Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · US incorporation, India-US DTAA, FEMA ODI, NRI taxation, cross-border structuring · LinkedIn

/ The deactivated DIN problem

What breaks.

MCA eForm filings blocked: AOC-4, MGT-7, DIR-12, PAS-3, PAS-6, SH-7, CHG-1/4, INC-22 - cannot be filed. Essentially all year-end ROC compliance.
Signing authority gone: director cannot sign board resolutions on MCA records.
Bank KYC refresh fails: director KYC with Indian banks requires active DIN.
Incorporation of new company blocked: cannot be appointed director of new company.
Form PAS-6 half-year filing blocked: for Rule 9B demat companies - November 29 PAS-6 deadline missed if DIN deactivated.

/ The fix

Simple + fast.

DIR-3 KYC filing via MCA v3 portal:
— DIR-3 KYC Web: for returning filers with unchanged KYC details (name, DOB, nationality, email, mobile, address, PAN, Aadhaar). Login with DSC or MCA credentials; OTP verification; submit.
— DIR-3 KYC eForm: for first-time filers or KYC changes. Download, attach documents (PAN, Aadhaar, address proof), self-attest, apply DSC, upload.
Late fee: INR 5,000 via MCA portal.
Reactivation: 24-72 hours after filing processed.
Then: proceed with year-end ROC filings.

/ Common catch-up scenarios

Who missed + why.

Directors who moved abroad / changed address - didn't receive MCA notification emails.
Resigned directors who thought DIN automatically deactivated (it doesn't).
Directors with multiple directorships who assumed another company's team was handling.
First-time directors unaware of DIR-3 KYC annual filing requirement.
Directors with DSC expired / lost - deferred DIR-3 KYC while sorting DSC + ended up missing deadline.

/ Timing matters

Why November-December urgent.

AOC-4 due 30 October 2026 (post AGM). Many companies filing in November - need active DIN.
MGT-7 due 29 November 2026 (60 days post AGM). Needs active DIN.
PAS-6 for Rule 9B demat companies due 29 November 2026. Needs active DIN.
DPT-3 due later in year but needs active DIN.
MSME Form I due 29 November 2026. Needs active DIN.
Section 148A show-cause response (if received) - needs active DIN to e-file response.

Fix DIN first, then execute year-end compliance.

Last updated: 2026-10-22.

/ Ready when you are

Director DIN deactivated? Fix urgently - blocks all MCA filings.

DIR-3 KYC + INR 5,000 late fee + 24-72 hour reactivation. Then AOC-4 + MGT-7 + PAS-6 + MSME Form I year-end sequence. BQP integrated.

Get a firm quote → WhatsApp Durgesh

FAQ

Common questions, answered.

I missed DIR-3 KYC deadline 30 September 2026. What now?

File DIR-3 KYC (Web or eForm) with INR 5,000 late fee via MCA v3 portal. DIN reactivated within 24-72 hours after filing. Then proceed with normal MCA filings (AOC-4, MGT-7, DIR-12, PAS-6, etc.). Fix urgently - all MCA eForm filings blocked until DIN reactivated.

What's the late fee for DIR-3 KYC catch-up?

INR 5,000 standard late fee irrespective of delay duration. Paid via MCA v3 portal during DIR-3 KYC filing. No multiplier for extended delay (unlike some other MCA late fees).

Can I file AOC-4 if my DIN is deactivated?

No - all MCA eForm filings require active DIN of the authorised signatory. AOC-4 + MGT-7 + DIR-12 + PAS-3 + PAS-6 + SH-7 + CHG-1/4 + INC-22 all blocked. Fix DIR-3 KYC first; then DIN reactivation; then AOC-4 filing.

Does DIR-3 KYC also apply to foreign directors?

Yes - every DIN holder (Indian or foreign resident) must file DIR-3 KYC annually. Foreign directors can file DIR-3 KYC Web (if returning filer with unchanged KYC) or eForm (first time / changed details). Documents: foreign passport + apostilled address proof. Fee + deadline same.

Will my DIN be deactivated again next year if I don't file DIR-3 KYC?

Yes - DIR-3 KYC is annual mandatory. Each year's DIR-3 KYC due 30 September for all DINs allotted on or before 31 March of preceding FY. BQP maintains client director DIR-3 KYC calendar + annual compliance reminder.

Does BQP handle DIR-3 KYC catch-up + year-end ROC filings coordinated?

Yes - urgent catch-up + full year-end ROC package. DIR-3 KYC catch-up (24-72 hour DIN reactivation) + AOC-4 + MGT-7 + DIR-12 + PAS-6 + DPT-3 + MSME Form I + MGT-14. One firm, one calendar, no gaps. WhatsApp +91 78018 87130.