India Compliance Calendar: Every Filing Deadline for FY 2025-26

Introduction

India's regulatory framework requires companies to make filings with at least five to seven different government agencies throughout the year. For a foreign-owned subsidiary, the number of filings can exceed 60 per year when you factor in monthly TDS deposits, GST returns, quarterly TDS returns, advance tax installments, ROC annual filings, the statutory audit, the Annual General Meeting, and the full suite of FEMA and RBI reporting obligations.

The penalties for non-compliance are not trivial. Late TDS deposits attract interest at 1.5% per month calculated from the date of deduction. Late ROC filings attract Rs 100 per day with no cap. Late FEMA reporting can trigger penalties up to three times the contravention amount. And the consequences extend beyond financial penalties — directors with deactivated DINs cannot sign any MCA forms, companies that miss AGM deadlines face NCLT proceedings, and persistent non-compliance can lead to the company being struck off by the Registrar.

This compliance calendar covers every deadline for FY 2025-26 (April 1, 2025 to March 31, 2026), organized month by month. Assessment year deadlines (for FY 2025-26 filings that fall in FY 2026-27) are included in the relevant months.

Monthly Recurring Deadlines

Before diving into the month-by-month calendar, here are the deadlines that recur every month without exception:

Month-by-Month Compliance Calendar: FY 2025-26

April 2025

May 2025

June 2025

July 2025

August 2025

September 2025

October 2025

November 2025

December 2025

January 2026

February 2026

March 2026

Post-FY 2025-26 Deadlines (Assessment Year 2026-27)

The following deadlines fall in FY 2026-27 but relate to FY 2025-26 filings:

Special Section: Foreign Subsidiary Additional Deadlines

Companies with foreign direct investment face an additional layer of compliance beyond what domestic companies manage. These deadlines are governed by FEMA and RBI Master Directions.

Event-Based FEMA Filings (No Fixed Calendar Date)

Annual FEMA/RBI Filings

Quarterly TDS Compliance: Detailed Walkthrough

TDS (Tax Deducted at Source) is one of the most frequent and penalty-heavy compliance requirements. Understanding the complete TDS cycle helps prevent the most common compliance failures.

Monthly TDS Deposit Process

Every payment subject to TDS must have tax deducted at the time of payment or credit (whichever is earlier). The deducted amount must be deposited with the government by the 7th of the following month using Challan 281 through the e-Pay Tax portal. For the month of March, the deadline extends to April 30 for certain categories.

The TDS rates vary by payment type and recipient status. Key rates for FY 2025-26 include:

For foreign subsidiaries, Section 195 is particularly important as it governs TDS on all payments to non-residents, including the foreign parent company. Incorrect TDS deduction on payments to the parent (royalties, management fees, intercompany charges) is one of the most common audit findings.

Quarterly TDS Return Filing

After depositing TDS monthly, quarterly returns must be filed summarizing all deductions made during the quarter:

• Form 24Q — TDS on salary payments (Section 192). Filed quarterly with the annual statement in Q4.
• Form 26Q — TDS on non-salary payments to residents (Sections 194A through 194T).
• Form 27Q — TDS on payments to non-residents (Section 195 and others). This form is critical for foreign subsidiaries making payments to the parent company or other overseas entities.

Each return must reconcile the total TDS deducted and deposited during the quarter with the challans paid. Mismatches between the TDS return and challan data are a common error that triggers demand notices from the Income Tax Department.

TDS Certificates

After filing TDS returns, the deductor must issue TDS certificates to deductees:

• Form 16 — Annual salary TDS certificate, due by June 15 following the financial year.
• Form 16A — Quarterly non-salary TDS certificate, due within 15 days of the TDS return filing deadline.
• Form 16A for non-residents — Issued based on Form 27Q filing. Non-resident payees often need these certificates for claiming tax credits in their home country under the applicable DTAA.

GST Compliance: Monthly vs Quarterly Filing

The GST compliance burden depends on the taxpayer's aggregate turnover and the filing scheme opted for.

Monthly Filing (Mandatory for Turnover > Rs 5 Crore)

Companies with annual aggregate turnover exceeding Rs 5 crore must file returns monthly. The cycle involves: GSTR-1 (details of outward supplies — sales invoices) by the 11th, which feeds into the recipient's GSTR-2A/2B for input tax credit matching, followed by GSTR-3B (summary return with tax payment) by the 20th. The two returns serve different purposes — GSTR-1 is an information return for invoice-level reporting, while GSTR-3B is the liability and payment return.

Quarterly Filing under QRMP Scheme

Taxpayers with turnover up to Rs 5 crore can opt for the Quarterly Return Monthly Payment (QRMP) scheme. Under this scheme, GSTR-1 is filed quarterly (by the 13th of the month after the quarter), and GSTR-3B is also filed quarterly (by the 22nd or 24th, depending on the state category). However, tax payments are still made monthly — by the 25th of the following month using the PMT-06 challan. The QRMP scheme offers the Invoice Furnishing Facility (IFF) for reporting invoices in the first two months of each quarter, enabling recipients to claim input tax credit without waiting for the quarterly return.

Annual GST Return and Reconciliation

All registered taxpayers must file GSTR-9 (annual return) by December 31. Taxpayers with turnover exceeding Rs 5 crore must also self-certify and file GSTR-9C (reconciliation statement) — reconciling the figures in GSTR-9 with the audited financial statements. Common discrepancies arise from: timing differences between GST reporting and accounting recognition, classification differences (exempt vs taxable supply), and input tax credit reversals. It is advisable to perform monthly reconciliation between the books and GST returns to avoid a large reconciliation exercise at year-end.

ROC Annual Filing: Step-by-Step

The MCA annual filing cycle follows a structured sequence that begins with the statutory audit and culminates in the filing of annual returns.

Step 1: Complete the Statutory Audit (April-August)

The statutory auditor (appointed under Section 139) conducts the audit of financial statements prepared under Schedule III of the Companies Act 2013. For companies with foreign parents that also require consolidated reporting, the Indian subsidiary's financials may need to be prepared under both Indian Accounting Standards (Ind AS) and the parent's reporting framework (US GAAP, IFRS). The audit should ideally be completed by August to allow sufficient time for AGM preparation.

Step 2: Hold the Annual General Meeting (by September 30)

The AGM is convened with at least 21 clear days' notice to all members. The agenda must include: adoption of audited financial statements and auditor's report, declaration of dividend (if any), appointment or reappointment of directors retiring by rotation, and reappointment of the statutory auditor (or ratification). For foreign-owned subsidiaries, shareholder resolutions often include approval for related party transactions (Section 188) with the foreign parent, which require ordinary resolution in most cases.

Step 3: File AOC-4 (within 30 days of AGM)

AOC-4 is the e-form for filing financial statements (Balance Sheet, Profit & Loss Account, Cash Flow Statement, and notes) with the ROC. Companies falling under the prescribed class must file in XBRL format (AOC-4 XBRL). The filing must include the Board's report, auditor's report, and the financial statements as adopted at the AGM. Late filing attracts Rs 100 per day per form with no maximum cap — making prolonged delays extremely expensive.

Step 4: File MGT-7 (within 60 days of AGM)

MGT-7 (or MGT-7A for small companies and one-person companies) captures the company's annual return including: shareholding pattern, director details, meeting details, and compliance disclosures. This form must be certified by a Company Secretary in practice for companies with a paid-up share capital of Rs 10 crore or more, or turnover of Rs 50 crore or more.

Step 5: File DIR-3 KYC (by September 30)

Every director holding a DIN as of March 31 must complete the annual DIR-3 KYC. First-time filers use the DIR-3 KYC web form; subsequent filings use DIR-3 KYC-WEB (a simpler update-only form). Foreign directors must ensure their passport details are current on the MCA database. If a director's passport has been renewed since the last KYC filing, the DIR-3 KYC form must reflect the updated passport number.

Transfer Pricing Compliance for Foreign Subsidiaries

Companies with international transactions exceeding the prescribed threshold must comply with India's transfer pricing regulations under Sections 92 to 92F of the Income Tax Act.

Documentation Requirements

Transfer pricing documentation must be maintained contemporaneously (i.e., prepared before the due date for filing the income tax return, not retrospectively). The documentation includes: a master file (global overview of the multinational group), a local file (detailed analysis of the Indian entity's international transactions), and — for large MNE groups — a Country-by-Country Report (CbCR). The documentation must demonstrate that all international transactions are priced at arm's length using prescribed methods (CUP, RPM, CPM, TNMM, or PSM).

Form 3CEB: Transfer Pricing Audit Report

A Chartered Accountant must certify Form 3CEB — the transfer pricing audit report — by October 31 of the assessment year. This report details all international transactions and specified domestic transactions, the methods applied, and the CA's conclusions on arm's length pricing. Companies with transfer pricing obligations get an extended ITR filing deadline of November 30 (instead of the standard October 31 for companies).

Common International Transactions Subject to TP

• Purchase or sale of goods between the subsidiary and the parent
• Payment of royalties, license fees, or brand usage fees to the parent
• Management fees or shared service charges allocated by the parent
• Intercompany loans and guarantees (interest rate must be at arm's length)
• Cost-sharing or cost-contribution arrangements
• Provision of technical or consultancy services

The Indian tax authorities have been increasingly aggressive in transfer pricing assessments. Foreign subsidiaries should ensure their transfer pricing documentation is robust, with proper benchmarking studies updated annually.

Key Regulations and Legal Framework

The compliance deadlines in this calendar are governed by the following legislation:

• Income Tax Act, 1961 — Governs TDS (Sections 192-206C), advance tax (Section 208-211), income tax return filing (Section 139), and penalties for non-compliance (Sections 234A, 234B, 234C, 234E, 234F, 271H, 276B).
• Central Goods and Services Tax Act, 2017 — Governs GST return filing (Sections 37-44), penalties for late filing (Section 47), and interest on late tax payment (Section 50).
• Companies Act, 2013 — Governs AGM (Section 96), Board meetings (Section 173), statutory audit (Section 139-147), financial statement filing (Section 137), annual return (Section 92), books of accounts (Section 128), and various penalty provisions.
• Foreign Exchange Management Act, 1999 — Governs all foreign investment reporting including FC-GPR, FC-TRS, FLA returns, and downstream investment reporting. Penalties under Section 13.
• RBI Master Direction on Foreign Investment in India (January 4, 2018, as amended) — Consolidated direction on FDI pricing, reporting, and compliance.
• Employees' Provident Funds and Miscellaneous Provisions Act, 1952 — Governs PF contribution deadlines and penalties.
• Employees' State Insurance Act, 1948 — Governs ESI contribution deadlines.

Common Mistakes to Avoid

• Confusing financial year with assessment year — FY 2025-26 is the year of income (April 2025 to March 2026). AY 2026-27 is the year of assessment when returns are filed and taxes are assessed. Income tax returns and TDS returns reference the assessment year.
• Missing the TDS deposit on the 7th — TDS must be deposited by the 7th of the following month. Interest is charged at 1.5% per month from the date of deduction (not from the due date). Even a one-day delay triggers one full month of interest.
• Filing GSTR-1 late and blocking GSTR-3B — GSTR-3B cannot be filed if GSTR-1 is pending. Late GSTR-1 therefore cascades into late GSTR-3B, doubling the penalties.
• Not filing FLA even when there are no transactions — The FLA return must be filed every year as long as the company has foreign investment, even if no new investment or transactions occurred during the year.
• Treating the AGM as optional — The AGM is a statutory requirement, and missing it is a non-compoundable offence. Even a one-person subsidiary of a foreign company must hold its AGM on time.
• Ignoring DIR-3 KYC for foreign directors — Foreign directors holding DIN must also complete DIR-3 KYC. They can use their passport as identity proof. If the KYC is missed, the DIN is deactivated, preventing the director from approving any MCA filings.
• Not maintaining advance tax installment discipline — Many companies pay the entire tax at year-end rather than in quarterly installments. This triggers interest under Sections 234B and 234C, which compounds at 1% per month.

Practical Tips for Managing Compliance

1. Appoint a compliance officer or engage a professional firm — For foreign subsidiaries, a Chartered Accountant or Company Secretary firm that specializes in FEMA compliance is essential.
2. Set up automated reminders — Configure calendar alerts at least 7 days before each deadline to allow time for preparation and filing.
3. Maintain a filing tracker — Track every filing with its due date, actual filing date, acknowledgement number, and the responsible person.
4. Complete the statutory audit early — Do not wait until September to begin the audit. Starting the audit in May or June gives adequate time for queries, corrections, and timely AGM preparation.
5. Keep FEMA documentation organized — Maintain a separate FEMA file with all FIRCs, FC-GPR acknowledgements, share valuation reports, and board resolutions authorizing share allotments. This file is needed during audits and any RBI inspection.
6. Review CBDT notifications regularly — CBDT frequently extends ITR filing deadlines. While this guide uses statutory deadlines, actual deadlines may be extended through official notifications.

Compliance Costs and Budget Planning

Understanding the financial cost of compliance helps foreign subsidiaries budget appropriately. Beyond the direct penalties for non-compliance, there are recurring costs for maintaining a clean compliance record.

Recurring Annual Compliance Costs

For a typical foreign subsidiary with 10-50 employees and annual turnover under Rs 10 crore, total annual compliance costs (including professional fees for all filings, statutory audit, and tax compliance) typically range from Rs 5 lakh to Rs 15 lakh (approximately USD 6,000 to USD 18,000). Companies with transfer pricing obligations, complex intercompany transactions, or operations in multiple Indian states will be at the higher end of this range. These costs should be factored into the business plan from the outset, as compliance is a non-negotiable operating expense for any Indian company.