Form AOC-4 NBFC: Complete Guide to Filing Financial Statements for Ind AS NBFCs
Form AOC-4 NBFC is the web form filed with the Registrar of Companies by Non-Banking Financial Companies (NBFCs) to which Indian Accounting Standards (Ind AS) apply, for annual filing of their 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 NBFC / When is it Filed
Every NBFC, as defined under the Companies (Indian Accounting Standards) (Amendment) Rules, 2016, to which Ind AS applies, must file its financial statements (including consolidated statements and mandatory attachments) via AOC-4 NBFC. If not adopted at the AGM, un-adopted financial statements must be filed within 30 days of the AGM date (or its due date). Once adopted, the adopted statements must be filed within 30 days of the AGM (actual or adjourned). Revised financial statements under Sections 130 or 131 are also filed via this form.
Linked Forms
| Linked Form | Description | When Applicable |
|---|---|---|
| AOC-1 | Statement of salient features of subsidiaries/associates/JVs | Company has a subsidiary, associate, or joint venture |
| AOC-2 | Disclosure of related-party contracts/arrangements | ‘Yes’ selected for related-party transactions |
| AOC-4 NBFC CFS | Consolidated financial statements | ‘Yes’ selected for consolidated financial statements required |
| CSR-2 | CSR reporting | CSR applicability under Section 135 (or unspent CSR amount reporting), for FY 2024-25 onwards, and not a provisional/un-adopted filing |
| Extract of Board’s Report | Extract of the Board’s report | Applicable in all cases |
| Extract of Auditor’s Report (Standalone) | Extract of the auditor’s report | Applicable in all cases |
| Extract of Auditor’s Report (Consolidated) | Extract of the auditor’s report on consolidated statements | Where a consolidated AOC-4 (AOC-4 CFS/AOC-4 NBFC CFS) is filed |
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
- 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
- Authorised signatories must hold an approved DIN or valid PAN or Membership number
- The company must not be flagged for non-filing of Form INC-22 (where applicable)
- No other AOC-4 NBFC filing should already be pending for payment, pending for approval, or already approved for the same financial year end date
- The CIN status must not be strike-off, amalgamated, converted to LLP, dormant, dissolved, liquidated, or otherwise unavailable for e-filing
- The certifying professional’s membership/certificate of practice number must be valid for their category
- 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 NBFC (Ind AS)
- Enter/search/select CIN
- Fill up the application, indicating applicability of linked forms
- Complete and attach the applicable linked forms
- 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
- 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 | Revised financial statements under Section 130 or Section 131 |
| STP | All other cases — taken on record electronically without further processing; no provision for resubmission |
Useful Links
Frequently Asked Questions (FAQs)
Q1. Who must file AOC-4 NBFC instead of AOC-4? NBFCs to which Indian Accounting Standards apply, as defined under the Companies (Indian Accounting Standards) (Amendment) Rules, 2016.
Q2. What linked forms might accompany AOC-4 NBFC? AOC-1 (subsidiaries/JVs), AOC-2 (related-party transactions), AOC-4 NBFC CFS (consolidated statements), CSR-2, and the Board’s/Auditor’s Report extracts, depending on answers given in the form.
Q3. Unlike AOC-4, does AOC-4 NBFC have a “reduction in paid-up capital” Non-STP trigger? No — for AOC-4 NBFC, only revised financial statements under Sections 130/131 trigger Non-STP processing; the paid-up capital reduction trigger listed for AOC-4 is not listed for AOC-4 NBFC.
Q4. Is AOC-4 NBFC processed automatically in most cases? Yes, non-revised filings are STP with no resubmission facility.
Q5. What is the daily delay fee for late filing? ₹100 per day beyond the statutory due date (applicable for delays after 30 June 2018).
Disclaimer
This article is based on the official Instruction Kit for Form AOC-4 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 NBFC and resources available on the MCA website.