Form AOC-4 CFS NBFC: Complete Guide to Filing Consolidated Financial Statements of NBFCs
Form AOC-4 CFS NBFC is the web form filed with the Registrar of Companies for Ind AS Non-Banking Financial Companies (NBFCs) with subsidiaries to file their consolidated financial statements. It is governed by Section 137 of the Companies Act, 2013 read with Rule 12(1A) of the Companies (Accounts) Rules, 2014.
Who Should File AOC-4 CFS NBFC / When is it Filed
Every NBFC (Ind AS) company with one or more subsidiaries must prepare consolidated financial statements and, once adopted at the AGM, file them via AOC-4 CFS NBFC within 30 days of the AGM. If not adopted, un-adopted statements must be filed within 30 days of the AGM date (or its due date if the AGM was not held). Revised consolidated financial statements under Sections 130 or 131 are also filed via this form. Filing is only permitted where the current financial year ‘From date’ is on or after 1 April 2018.
Linked Form
Extract of Auditor’s Report (Consolidated) applies wherever a consolidated AOC-4 is filed, including via AOC-4 CFS NBFC.
Important Checkpoints Before Filing
- Applicant must be registered as a Business User on the MCA portal before filing
- The company must hold a valid, approved CIN, which may be Active, Under CIRP, or Under Liquidation
- The DSC attached must be registered on the MCA portal against the DIN/PAN/Membership number provided
- The signing authority must hold a valid, non-expired, non-revoked DSC
- A valid SRN of AOC-4 NBFC (Ind AS) for the same financial year must be available and quoted
- No other AOC-4 CFS NBFC should already be approved or pending payment/approval against the same AOC-4 NBFC SRN
- Filing is allowed only where the financial year ‘From date’ is on or after 1 April 2018
- The CIN status must not be strike-off, amalgamated, converted to LLP, dormant, dissolved, liquidated, or otherwise unavailable for e-filing
- There must be no overlap in the financial year period with any other approved (non-defective) annual filing
- SRNs of ADT-1/INC-28/AOC-4 NBFC/MGT-14/GNL-1/AOC-4 NBFC CFS, wherever applicable, must be approved and associated with the company
- The FY start and end dates must fall within the period entered in field 4(i) of Form ADT-1
- A valid membership number must be entered in the auditors’ section
- Where the company is Under CIRP or Under Liquidation, only the IRP/RP/Liquidator may sign the form with their DSC
- For resubmission: application must be in Application History and T+15 days (T = date marked ‘Resubmission Required’) must not have elapsed
Step-by-Step Filing Process
- Login to MCA portal → MCA Services → E-Filing → Annual Filings
- Access Form No. AOC-4 CFS NBFC
- Enter/search/select CIN, quoting the corresponding AOC-4 NBFC SRN
- Fill up the application with consolidated financial statement details
- Optionally save as draft
- Submit the webform and note the SRN
- Affix DSC
- Upload the DSC-affixed PDF on MCA portal
- Pay Fees
- Receive acknowledgement
Signing Requirements
- Digitally signed by an authorised signatory with an approved DIN or valid PAN/Membership number
- Where the company is Under CIRP/Under Liquidation, only the IRP/RP/Liquidator may sign
- Certification by a practicing professional with a valid membership/certificate of practice number
Fee Structure
Normal Fee — Companies with Share Capital
| Nominal Share Capital (INR) | Fee (INR) |
|---|---|
| Less than 1,00,000 | 200 |
| 1,00,000 to 4,99,999 | 300 |
| 5,00,000 to 24,99,999 | 400 |
| 25,00,000 to 99,99,999 | 500 |
| 1,00,00,000 or more | 600 |
Companies without share capital: ₹200
Additional (Delay) Fee — Beyond 30 June 2018
| Basis | Additional Fee |
|---|---|
| Delay beyond the period under Section 92(4) | ₹100 per day |
| Delay beyond the period under Section 137(1) | ₹100 per day |
Additional (Delay) Fee — Belated Filings Up to 30 June 2018
| Period of Delay | Additional Fee |
|---|---|
| Up to 30 days | 2× normal fee |
| More than 30 up to 60 days | 4× normal fee |
| More than 60 up to 90 days | 6× normal fee |
| More than 90 up to 180 days | 10× normal fee |
| More than 180 days | 12× normal fee |
Processing Mode
| Mode | When Applicable |
|---|---|
| Non-STP | The linked AOC-4 NBFC (Ind AS) filing is itself processed in Non-STP mode |
| STP | The linked AOC-4 NBFC (Ind AS) filing is processed in STP mode — taken on record electronically without further processing; no provision for resubmission |
Useful Links
Frequently Asked Questions (FAQs)
Q1. Which companies must file AOC-4 CFS NBFC? Ind AS NBFCs that have one or more subsidiaries and are therefore required to prepare consolidated financial statements.
Q2. Is an AOC-4 NBFC SRN required before filing AOC-4 CFS NBFC? Yes, a valid SRN of AOC-4 NBFC (Ind AS) for the same financial year must be quoted.
Q3. What is the earliest financial year this form can be used for? Filing is only permitted where the current financial year ‘From date’ is on or after 1 April 2018.
Q4. How is processing mode determined for AOC-4 CFS NBFC? It follows the processing mode (STP or Non-STP) of the linked AOC-4 NBFC (Ind AS) filing.
Q5. Who can sign this form for a company under CIRP or liquidation? Only the Interim Resolution Professional, Resolution Professional, or Liquidator, using their own DSC.
Disclaimer
This article is based on the official Instruction Kit for Form AOC-4 CFS NBFC published by the Ministry of Corporate Affairs (MCA), Government of India. While every effort has been made to ensure accuracy, the content is intended for general guidance purposes only. MCA forms, rules, and fee structures are subject to change through amendments to the Companies Act, 2013 or notifications issued thereunder.
In case of any inconsistency or doubt, readers are advised to refer to the official MCA access page for AOC-4 CFS NBFC and resources available on the MCA website.