• Saurabh Kesarwani
  • img March 20, 2026

FAQs on MGT-7 & MGT-7A

This FAQ explains the key aspects of Form MGT-7 and Form MGT-7A, which are used for filing the annual return of a company under the Companies Act, 2013. It covers the applicability of each form (MGT-7 for companies other than OPCs and AOCs, and MGT-7A for OPCs and AOCs), statutory due dates, major disclosures, certification requirements, and consequences of delay or non-filing. The FAQ helps companies and professionals understand their annual return filing obligations and ensure timely compliance with the Ministry of Corporate Affairs and the Registrar of Companies (ROC).

1) Are there any file size limit exceptions for Annual filing forms?next

1. ‘List of shareholders, debenture holders’ excel attachment size limit is increased to 300 MB in MGT-7 [15 files of 20 MB each]. Generated PDF will not have List of shareholders, debenture holders excel as an attachment. However, data uploaded in these excels will be stored in the system.
2. 2 MB limit of each attachment is removed in the following forms. Attachments can be uploaded beyond 2 MB subject to overall form size limit including all attachments is 10 MB except overall size limit of AOC-4 XBRL is 20 MB.
• AOC-4 • AOC-4 XBRL
• AOC-4 NBFC
• AOC-4 CFS
• AOC-4 NBFC CFS
3. All other forms attachments and form size limit would continue as the normal process i.e. each attachment size is restricted to 2 MB and the overall form size including all attachments is 10 MB

2) What is excel functionality is Online web form for MGT-7/MGT-7A? Which all sections have this functionality?next

Excel functionality in Online web form refers to providing details which are in the format of Table through macro enabled excel. Once user enters the number in the relevant field, excel download option would be enabled to fill in the details in excel with required validation. Below are sections where Excel functionality is implemented in Online web form.
• MGT-7 III PARTICULARS OF HOLDING, SUBSIDIARY AND ASSOCIATE COMPANIES (INCLUDING JOINT VENTURES) Form field
• MGT-7 IX-A MEMBERS/CLASS /REQUISITIONED/NCLT/COURT CONVENED MEETINGS Form field
• MGT-7 IX-B BOARD MEETINGS Form field
• MGT-7 IX-C COMMITTEE MEETINGS Form field
• MGT-7 IV: iii Details of shares/Debentures Transfers since closure date of last financial year (or in the case of the first return at any time since the incorporation of the company) -Details of shares/Debentures Transfers Attachment
• MGT-7 XIV Attachments - List of shareholders, debenture holders Attachment
• MGT-7A III PARTICULARS OF ASSOCIATE COMPANIES (INCLUDING JOINT VENTURES) (not applicable for OPC) Form field
• MGT-7A XIII - A MEMBERS/CLASS /REQUISITIONED/NCLT/COURT CONVENED MEETINGS Form field
• MGT-7A XIII-B BOARD MEETINGS Form field
• MGT-7A XIII Attachments - List of shareholders, debenture holders Attachment
• MGT-7A IV: ii Details of shares/Debentures Transfers since closure date of last financial year (or in the case of the first return at any time since the incorporation of the company) (not applicable for OPC) Attachment

3) What are the key points to be noted in case of any issue with respect to small company while filing annual filing forms?next

• Small company logic is checked as on the date of filing of the form.
• Companies are required to file their annual filing forms in sequential manner in case small company flag changes are there in subsequent year filings.
• Holding and/or subsidiary details to be provided correctly in AOC-4/AOC-4 XBRL/AOC-4 NBFC.
• If there is any change in small company flag due to Turnover, Paid-up capital, holding company, subsidiary company, same would get updated only after approval of AOC-4/AOC-4 XBRL/AOC-4 NBFC/MGT-7/MGT-7A.
• In case small company flag is ‘No’ in the system due to previous year filings and become small company during the current reporting period, company has to file AOC-4/AOC-4 XBRL/AOC-4 NBFC form [with professional certification] and upon approval, small company flag will be set to ‘Yes’.
• In case small company becomes holding or subsidiary company during the current reporting period, company has to file AOC-4/AOC-4 XBRL/AOC-4 NBFC to update small company flag as ‘No’ and then proceed to file MGT-7.
• In case normal company become small company, company has to file AOC-4/AOC-4 XBRL/AOC-4 NBFC to update small company flag as ‘Yes and then proceed to file MGT-7A.

4) What is the process of uploading Shareholder/Debenture holder details in MGT-7/MGT-7A?next

List of Shareholders/Debenture holders [if applicable] shall be attached within the form while filing MGT-7/MGT-7A.
This attachment can be uploaded either in macro-enabled pre-defined sheet or normal excel sheet or CSV without in any validations/conditions.
For MGT-7, excel files are allowed up to 300 MB [15 files of 20 MB each]and for MGT-7A, excel file size should be up to 2 MB only.

5) MGT-7 allows Shareholder/Debenture holder excels up to 300 MB. Whether generated PDF display such large excel files?next

The V3 MCA portal allows uploading up to 15 Excel files in MGT-7, each with a maximum size of 20 MB, totalling 300 MB. These files can be either macro-enabled predefined sheets or normal Excel sheets or CSV without in any validations/conditions. While the portal accepts large Excel uploads, the generated PDF of MGT-7 does not embed or display the full content of these Excel files. Instead, the PDF includes a reference to the uploaded attachment, typically showing the file name which cannot be not opened. However, the MCA system is designed to store and validate the Excel data separately in its backend.

6) Is it mandatory to attach Photograph of the registered office of the Company while filing MGT-7/MGT-7A? If yes, which date shall be considered while uploading this photograph, as on the end of the relevant FY or as on date of filing?next

Yes. It is mandatory to attach latest ‘Photograph of the registered office of the Company showing external building and name & address prominently visible’ as aligned with the requirements specified in Section 12(3)(a) of the Companies Act-2013.

7) My registered office is situated in a multi-storied building; the name board will not be outside the building. How do I attach the Photograph in this case?next

Any photographs taken for this purpose are aligned with the requirements specified in Section 12(3)(a) of the Companies Act, 2013.

8) Is it mandatory to provide Gender wise Shareholders count in MGT-7/MGT-7A?next

Yes, it is mandatory to provide Gender wise breakup of number of Shareholders in MGT-7 and MGT-7A. However, Gender field is Optional in 'List of shareholders /Debenture holders' pre-defined excel.

9) MGT-8 is part of MGT-7 now. If there is any observation/remark, how to provide such information in the form?next

Form MGT-8, previously a separate certification by a Company Secretary in Practice, is now embedded within MGT-7 for companies meeting the criteria under Section 92(2) of the Companies Act, 2013—i.e., listed companies or those with paid-up capital ≥ ₹10 crore or turnover ≥ ₹50 crore. Further, the embedded MGT-8 portion includes a certification statement by the Company Secretary. While this is mostly structured, any qualifying remarks about compliance can presently be added in the ‘Optional Attachment field.

10) Class, category, sub-category got prefilled as on date in MGT-7/MGT-7A. Will the system allow editing these fields these got changed after the relevant FY end date?next

Yes. All these fields are prefilled based on as on date information and are editable.
The MCA V3 portal prefills class, category, and sub-category fields based on the current date. However, this can lead to discrepancies when filing for a past financial year, especially if changes occurred after the FY-end. Hence, system allow editing of prefilled class, category, and sub-category fields to reflect the correct status as on the closure of the financial year.

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Saurabh Kesarwani

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A dedicated CS Trainee with a passion for corporate governance and the "fine print" of legal documentation. View Full Profile

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