Form DPT-3: Eligibility, Due date and Compliance Guide (MCA)

The deadline for Form DPT-3 for FY 2025-26 is 30 June 2026. If your company has any outstanding director loans, inter-company loans, customer advances, or promoter borrowings as on 31 March 2026, you must disclose them in this return, whether or not those amounts qualify as deposits under the Companies Act 2013. For early-stage startups to pre-IPO businesses, and the most common reason for late filing is the same every year: founders assume that since they have not accepted public deposits, the form does not apply. That assumption is wrong and expensive.

If you are unsure whether a specific receipt on your balance sheet needs to be disclosed in DPT-3, check against Rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules, 2014. If it does not fall under an exemption category, it is a deposit and must be reported. If it does fall under an exemption, it still needs to be reported as an exempted receipt. There is no category of outstanding receipt that escapes disclosure.

What is Form DPT-3?

Form DPT-3 is a statutory annual return filed by companies with the Ministry of Corporate Affairs (MCA) to report two things: outstanding amounts of money or loans that are not classified as deposits under the Companies Act 2013, and actual deposits accepted from the public during the year.

The form was introduced through an MCA notification dated 22 January 2019, which inserted sub-rule (3) in Rule 16A of the Companies (Acceptance of Deposits) Rules, 2014. The initial mandate was a one-time return covering receipts outstanding between 1 April 2014 and 31 March 2019, filed within 90 days of 31 March 2019. General Circular No. 05/2019 later revised the effective due date to 31 May 2019. Since that one-time return, DPT-3 has been required annually.

The legal authority for the form sits across:

• Section 73 of the Companies Act 2013 (prohibition on acceptance of deposits from the public)
• Section 76 and Section 76A (acceptance of deposits from members, and penalties)
• Rule 16 and Rule 16A, Companies (Acceptance of Deposits) Rules, 2014

For FY 2025-26, the form reports all amounts outstanding as on 31 March 2026 and must be filed by 30 June 2026 on the MCA V3 portal at mca.gov.in.

Who must file Form DPT-3?

Every company registered under the Companies Act 2013, other than a government company, must file Form DPT-3. This covers:

• Private Limited Companies
• One Person Companies (OPCs)
• Public Limited Companies
• Section 8 companies (non-profit organisations registered under the Act)

For a full list of annual MCA obligations that sit alongside DPT-3, see Treelife’s guide to compliances for a private limited company.

Filing is mandatory regardless of whether the company has accepted formal deposits. If any loan, advance, or receipt is outstanding as on 31 March, the company must file. Even if nothing is outstanding, filing a NIL return is strongly recommended as a compliance best practice, since the absence of a filed return is indistinguishable from non-compliance in an MCA inspection.

Who is exempt from filing?

The following categories are specifically excluded under Rule 1(3) of the Companies (Acceptance of Deposits) Rules, 2014:

• Government companies (as defined under Section 2(45) of the Companies Act 2013)
• Banking companies
• Non-Banking Financial Companies (NBFCs) registered with RBI
• Housing finance companies registered with the National Housing Bank
• Any other company specifically notified under the proviso to Section 73(1) of the Companies Act 2013

Note that being a startup recognised by DPIIT does not exempt a company from DPT-3 filing. Startup status affects only specific regulatory treatments; it does not override the MCA deposit return requirement.

Deposit vs. non-deposit: the distinction that determines what you report

This is where most companies make classification errors that get flagged during ROC scrutiny. The definition of “deposit” under Rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules, 2014 excludes a long list of common transaction types. The key point: exclusion from the deposit definition does not mean exclusion from the form. Every excluded amount that is outstanding as on 31 March still gets reported, just in the section for non-deposit receipts rather than the deposits section.

For startups and small companies, the transactions most commonly reported are:

• Loans from directors or their relatives
• Advances received from customers for supply of goods or services
• Inter-company loans
• Unsecured loans from promoters
• Subscription to securities and calls in advance
• Convertible notes of Rs 25 lakh or more received in a single tranche (relevant for startups)

The return captures what is outstanding as of 31 March each year. Even if a transaction has been partially repaid, the remaining balance must be disclosed.

Beyond these six categories, the full Rule 2(1)(c) exclusion list is broader. All of the following are also excluded from the deposit definition but remain reportable in DPT-3:

• Any amount received from the Central or State Government, or guaranteed by them, or from a foreign government or foreign bank
• Any loan or facility from a Public Financial Institution, Insurance Company, or bank
• Any amount received from another company (inter-company loans)
• Subscription to securities and calls in advance (including share application money, within the period permitted under the Act)
• Any amount received from a director of the company, or (in the case of a private company) from a relative of a director, who held that position at the time of lending, accompanied by a declaration that the amount was not borrowed
• Security deposits received from employees, not exceeding one year’s annual salary, as per the terms of employment
• Advances received in the ordinary course of business for supply of goods or provision of services, provided the advance is adjusted against such supply within 365 days of receipt
• Advances received for immovable property, adjusted against the property consideration per the terms of the agreement
• Security deposits for performance of contracts for supply of goods or provision of services
• Advances under long-term projects for supply of capital goods (except those covered under the immovable property clause)
• Advances for future services in the form of a warranty or maintenance contract, per written agreement, where the service period does not exceed five years or the period prevalent in common business practice (whichever is less)
• Advances received under directions of a sectoral regulator or Central/State Government
• Advances for subscriptions to publications (print or electronic), to be adjusted against receipt of the publication
• Unsecured loans brought in by promoters in pursuance of a lending financial institution’s stipulation
• Amounts received by a Nidhi Company under Section 406 of the Act
• Amounts received by way of chit subscription under the Chit Funds Act, 1982
• Amounts received from Alternate Investment Funds, Domestic Venture Capital Funds, Infrastructure Investment Trusts, Real Estate Investment Trusts, or Mutual Funds registered with SEBI
• Non-interest bearing amounts received and held in trust
• Convertible notes of Rs 25 lakh or more received by a startup company in a single tranche, repayable within five years or convertible into equity shares.

What is actually a deposit (and must be reported as such):

Any money received from the public, or from shareholders, under conditions of repayment falling under Section 73 or Section 76, where the receipt does not fit any of the exclusions above, constitutes a deposit. This includes unsecured fixed deposits from the public, recurring deposits, and any loan from a person who does not hold the position of director at the time of lending.

The practical test for a startup: If you have a director loan outstanding, it goes in the non-deposit section of DPT-3 (with the Rule 2(1)(c)(viii) exemption cited). If you have customer advances pending delivery beyond 365 days, those could slip into deposit territory. If a promoter brought in an unsecured loan not linked to a lending institution’s stipulation, check whether it qualifies under the promoter exclusion.

What are the two types of DPT-3 filing?

One-time return: This was a historical obligation covering outstanding receipts from 1 April 2014 to 31 March 2019, filed by 31 May 2019. Companies that were incorporated after that date or that have filed annually since then do not need to worry about this.

Annual return: DPT-3 must be filed on or before 30 June each year, covering the financial year ending 31 March. This is the ongoing obligation. The annual return is the relevant filing for FY 2025-26 (due 30 June 2026).

Form DPT-3 fields explained: what you are actually filling in

The MCA Form DPT-3 is available at the MCA e-filing portal. The full form can be accessed at https://www.mca.gov.in/content/mca/global/en/mca/e-filing/foreigncompany-deposits-and-Nidhi-services/DPT-3.html. Below is a field-by-field walkthrough mapped to what a typical private company or startup actually encounters.

Company information (Fields 1-6)

Field	What to enter
1(a) Corporate Identity Number (CIN)	Auto-populates company details on the MCA portal after entry
1(b) Global Location Number (GLN)	Optional; relevant only if your company uses a GLN for logistics/supply chain purposes
2(a) Name of the company	Auto-populated from CIN
2(b) Registered office address	Auto-populated from CIN
2(c) Email ID	The company’s official email registered with MCA
4 Public or Private company	Select the appropriate type
5 Government company	Almost all startup/private companies select “No”
6 Objects of the company	Brief description of the company’s main business; cross-reference your MOA

Field 3, Purpose of the form (critical: select the right option)

This is where many companies make errors. There are four options:

• Onetime Return for disclosure of details of outstanding money or loan received but not considered as deposits (only for the historical 2014-2019 period, this is now historical)
• Return of Deposit (if your company has accepted actual deposits from the public or members)
• Particulars of transactions by a company not considered as deposit as per Rule 2(1)(c) (if you have only exempted receipts, no actual deposits)
• Return of Deposit and Particulars of transactions by a company not considered as deposit (if you have both actual deposits and exempted receipts)

For most private limited companies and startups: select the third option (Particulars of transactions not considered as deposit) unless you have also accepted formal public deposits, in which case select the fourth option.

Field 8, Net Worth

The net worth calculation follows a specific formula:

Net Worth = [Paid-up Share Capital + Free Reserves + Securities Premium Account] minus [Accumulated Loss + Balance of Deferred Revenue Expenditure + Accumulated Unprovided Depreciation + Miscellaneous Expenses and Preliminary Expenses + Other Intangible Assets]

Source this from your latest audited balance sheet preceding the date of the return. For a return filed in June 2026, this will typically be the balance sheet for FY 2024-25 (audited by the time of filing).

Field 7, Whether deposits have been accepted from public (applicable in the web form version)

Select “No” for most startups. If you have accepted deposits under Section 76 from members, select “Yes” and complete the subsequent deposits section.

Fields 9-12, Particulars of deposits (complete only if actual deposits exist)

Field	What it captures
9(a) Total deposit holders as on 1 April	Opening count of depositors
9(b) Total deposit holders at year end	Closing count
10(a) Amount of existing deposits as on 1 April	Opening balance
10(b) Amount of deposits renewed during the year	Rollovers of matured deposits
10(c)(i) Secured deposits accepted during the year	New secured deposits with charge
10(c)(ii) Unsecured deposits accepted during the year	New unsecured deposits
10(d) Amount of deposits repaid during the year	Repayments made
10(e) Balance of deposits outstanding at year end	Closing balance
11(a) Deposits matured but not claimed	Aged matured deposits not withdrawn by depositor
11(b) Deposits matured, claimed but not paid	Disputed or pending payments

Startups and most private companies with no public deposits enter NIL in all of Fields 9-12.

Field 12/13, Particulars of liquid assets

Only relevant if the company holds public deposits. Companies must maintain liquid assets equivalent to 15% of deposits maturing during the current and next financial year. Eligible liquid assets include:

• Amount in current or other deposits account, free from charge or lien, with any scheduled bank
• Unencumbered securities of Central or State Government (at face value and market value)
• Unencumbered trust securities (at face value and market value)

Again, NIL for most startups.

Field 13/14, Particulars of charge

If a charge has been created on the company’s assets to secure deposits, enter: the date of entering the trust deed, the name of the trustee, a description of the property on which the charge is created, and the value of that property. The MCA web form also asks for the number of charges and the SRN of CHG-1/CHG-9 forms filed.

Field 15, Particulars of receipt of money or loan not considered as deposits (the critical section for most companies)

This is the most important section for startups and private companies. It is a detailed table with the following columns for each category of exempted receipt:

Column	What to enter
Opening balance	Amount outstanding at start of FY
Additional loan during the year	New receipts in this category
Repaid during the year	Repayments made
Any other adjustment	Accounting reclassifications, conversions, etc.
Closing balance	Amount outstanding as on 31 March
Loans outstanding less than or equal to 1 year	Ageing: short-term portion
Loans outstanding more than 1 year, less than 3 years	Ageing: medium-term portion
Loans outstanding more than 3 years	Ageing: long-term portion

Categories covered in this table (corresponding to Rule 2(1)(c) exemption sub-clauses) include amounts from Central/State Government, foreign governments, foreign banks, multilateral financial institutions, banking companies, public financial institutions, regional financial institutions, insurance companies, scheduled banks, other companies, share application money, director loans, employee security deposits, business advances (goods/services, immovable property, capital goods, warranty/maintenance), publication subscription advances, promoter unsecured loans, Nidhi companies, chit fund subscriptions, SEBI-registered funds (AIFs, VCFs, InvITs, REITs, mutual funds), and convertible notes from startups.

Field 16, Credit rating

If your company has obtained a credit rating for its deposits (required for public deposits), enter the rating agency name, the rating obtained, and the date. Not applicable for most startups.

Field 17, SRN of GNL form in which DPT-1 is filed

DPT-1 is an advertisement for inviting deposits. If your company has issued a circular or advertisement for deposits, the SRN of the GNL form through which DPT-1 was filed goes here.

Field 18, Total outstanding money or loan not considered as deposits

This is the aggregate of all closing balances across Field 15, representing your total non-deposit receipts outstanding as on 31 March.

What documents do you need to attach?

Document	When required
Auditor’s certificate	Mandatory for all filings; certifies that the amounts in the deposits and liquid assets sections are correct per the Companies Act 2013
Copy of trust deed	Required if a charge has been created on assets to secure deposits
Deposit insurance contract	Required if the company maintains deposit insurance
Copy of instrument creating the charge	Required if a charge exists
List of depositors (in Excel format per MCA template)	Required for companies with actual public deposits; list must separately identify deposits matured and cheque issued but not yet cleared
Details of liquid assets	Required if the company holds deposits maturing within the next year
Optional attachment	Any additional document supporting the return

For a startup or private company with only director loans and inter-company receipts: you need the auditor’s certificate and the optional attachment slot is available for any supporting schedules from your accounts.

Due date and filing fees for FY 2025-26

DPT-3 must be filed on or before 30 June each year, covering the financial year ending 31 March. For FY 2025-26, this means all amounts outstanding as on 31 March 2026 must be reported by 30 June 2026. To track DPT-3 alongside all other MCA and tax deadlines, refer to Treelife’s compliance calendar 2026. This applies to all eligible companies regardless of whether they have actual deposits or only exempted receipts.

Late fee slabs (accruing from 1 July 2026)

Period of delay	Additional fee
Up to 30 days	2 times normal fee
More than 30 days, up to 60 days	4 times normal fee
More than 60 days, up to 90 days	6 times normal fee
More than 90 days, up to 180 days	10 times normal fee
More than 180 days	12 times normal fee

The late fee compounds quickly. A company with paid-up capital of Rs 1 crore or more filing 91 days late pays Rs 6,000 (10 times Rs 600) in additional fees, on top of the normal fee, before accounting for any substantive penalty.

Penalties for non-compliance with Form DPT-3

Failure to file, or accepting deposits without complying with the rules, exposes both the company and its officers to significant penalties. There are two penalty tracks under the Companies Act 2013.

Table: penalty exposure for non-compliance

Provision	Penalty on company	Penalty on officers in default
Section 73 / Section 76A	Minimum Rs 1 crore or twice the deposit amount (whichever is lower); maximum Rs 10 crore	Imprisonment up to 7 years plus fine of Rs 25 lakh to Rs 2 crore
Rule 21, Deposit Rules	Fine up to Rs 5,000 + Rs 500 per day for continuing default	Same as company penalty

Officers and directors carry personal liability under these provisions. For a detailed breakdown of what that exposure means beyond DPT-3, see Treelife’s article on liabilities of directors under the Companies Act 2013.

The Section 73 penalty applies where the company has accepted amounts that qualify as deposits without complying with the rules, not merely for missing the form deadline. Rule 21 covers the procedural default of not filing the form. Both can apply simultaneously if the company has both accepted deposits improperly and failed to file.

For delay in paying the penalty once assessed: an initial fine of Rs 5,000 applies, with an additional Rs 500 per day until the penalty is discharged.

There is no settled regulatory position on whether a NIL return must be filed where a company has no outstanding receipts at all. The conservative and strongly recommended approach is to file a NIL return. An unfiled return looks identical to a late return from the MCA’s audit perspective.

How to file Form DPT-3 on MCA V3: step-by-step

Form DPT-3 is a web-based form filed on the MCA V3 portal. The process is as follows:

1. Log in at mca.gov.in using your Business User credentials (MCA registered user ID and password).
2. Navigate to: MCA Services > e-Filing > Deposit Related Filings > DPT-3 Webform.
3. Enter your CIN. The portal will auto-populate company name, registered address, and other master data from the MCA database.
4. Select the purpose of the form (Field 3) based on whether you have actual deposits, only exempted receipts, or both.
5. Fill in the net worth table using your latest audited balance sheet. Ensure the figures match the audited accounts exactly, as the auditor will certify these.
6. Complete the deposits section (Fields 9-12) if applicable, or enter NIL.
7. Complete Field 15 (non-deposit receipts) for every category of exempted receipt outstanding as on 31 March 2026. Enter the opening balance, additions, repayments, adjustments, and closing balance for each applicable category, along with the ageing split.
8. Enter particulars of charge (Field 13/14) if applicable.
9. Enter credit rating details (Field 16) if applicable.
10. Attach the auditor’s certificate (mandatory) and any other required documents. Each attachment is limited to 2 MB.
11. Affix the Digital Signature Certificate (DSC) of the authorised signatory. The form must be signed by a Director (using DIN), or the Manager/CEO/CFO (using DIN or PAN), or the Company Secretary (using membership number). The statutory auditor must also digitally sign the auditor’s certificate section.
12. Pay the applicable filing fee through the MCA payment gateway.
13. Submit the form. On acceptance, the MCA portal generates a Service Request Number (SRN) and sends an email acknowledgement from the Registrar of Companies. Save both.

Note: Sections 448 and 449 of the Companies Act 2013 provide for punishment for false statements and false evidence. The declaration in the form carries this notice explicitly.

What Treelife commonly sees in practice

The most frequent gap we encounter is companies that have received director loans or inter-company loans and have repaid them during the year, but carry a balance as on 31 March. Because the repayment happened, the founders assume there is nothing to disclose. There is: the closing balance, even a partially repaid one, must appear in Field 15.

The second common error is selecting the wrong purpose in Field 3. A company that has only director loans and customer advances should select “Particulars of transactions by a company not considered as deposit as per Rule 2(1)(c).” Selecting “Return of Deposit” when no actual public deposits exist creates a mismatch with the nil entries in Fields 9-12, which triggers scrutiny.

A third pattern we see in startups that have raised via convertible notes: the note amount must be disclosed under the convertible note category in Field 15, with the applicable Rule 2(1)(c) clause cited, and the ageing filled in correctly. If the note converts during the year, the opening balance, conversion as an adjustment, and NIL closing balance all need to be entered. Leaving the row blank when a historical note existed is not acceptable.

Frequently asked questions on MCA DPT-3

Q: Does DPT-3 apply to my startup if I have not accepted any public deposits?
A: Yes. Filing is mandatory for every non-government company regardless of whether formal deposits exist. If you have any outstanding director loans, inter-company loans, customer advances, or promoter loans as on 31 March, you must file. If nothing is outstanding, a NIL return is strongly recommended.

Q: Do I need to file a NIL return if there are no outstanding amounts?
A: There is no definitive regulatory ruling that mandates a NIL return where no amounts are outstanding. However, the conservative position is to file. An absent return and a late return look identical to the ROC, and a NIL return costs only the normal filing fee.

Q: What is the due date for DPT-3 for FY 2025-26?
A: 30 June 2026. This covers amounts outstanding as on 31 March 2026. No extension circular has been issued as on the date of this publication; verify on the MCA circulars page before assuming any extension applies.

Q: Does a director loan to a private limited company need to be disclosed in DPT-3?
A: Yes. It is excluded from the definition of “deposit” under Rule 2(1)(c)(viii), but it must still be reported in Field 15 as a non-deposit receipt. The director must also provide a declaration that the amount was not borrowed from any other source.

Q: What happens if a director who gave a loan resigns before the return is filed?
A: The exemption under Rule 2(1)(c)(viii) applies if the person was a director at the time the money was received. If the director has since resigned, the amount may no longer qualify for the exemption in future years, as it depends on the director’s status at the time of receipt, not at the time of filing. This is an area with limited settled interpretation; seek specific advice if this situation applies.

Q: Our startup received funding via a convertible note. Does that go in DPT-3?
A: Yes. Convertible notes of Rs 25 lakh or more received in a single tranche by a startup company, repayable within five years or convertible into equity, are excluded from the deposit definition under Rule 2(1)(c). They must still be disclosed in Field 15. If the note converted during the year, show the opening balance, the conversion as an adjustment, and NIL closing balance.

Q: Are inter-company loans between a holding company and its subsidiary reportable?
A: Yes. Any amount received from another company is excluded from the deposit definition under Rule 2(1)(c)(xi). However, it must be disclosed in Field 15 with the correct opening balance, additions, repayments, and closing balance, along with ageing.

Q: What if our customer advances have been outstanding for more than 365 days?
A: Customer advances are excluded from the deposit definition only if they are adjusted against supply of goods or provision of services within 365 days of receipt. If the 365-day window has passed without delivery, those advances may re-classify as deposits. This is a common compliance risk for SaaS and services companies with deferred revenue. Review aged advance balances before filing.

Q: Who signs Form DPT-3?
A: The form requires two digital signatures. The statutory auditor signs the auditor’s certificate section using their DSC and membership number. The company signatory can be a Director (using DIN), Manager/CEO/CFO (using DIN or PAN), or Company Secretary (using membership number). Board authorisation via resolution is required.

Q: What is the penalty if we file DPT-3 after the 30 June deadline?
A: Late filing fees apply from 1 July, on a multiplier of the normal filing fee ranging from 2x to 12x depending on the delay period (see the fee table above). If the delay also reveals that unclassified deposits were accepted, Section 73/76A penalties apply: minimum Rs 1 crore or twice the deposit amount, up to Rs 10 crore for the company, and imprisonment up to 7 years plus fine of Rs 25 lakh to Rs 2 crore for officers in default.

Q: Can DPT-3 non-compliance affect a funding round or acquisition due diligence?
A: Yes, directly. Standard MCA compliance searches during due diligence surface outstanding annual filing defaults. A missing DPT-3 is a red flag that raises questions about the broader compliance culture. It also creates a liability quantification problem: the acquirer or investor has to account for the potential penalty exposure in their valuation model. For a complete view of what investors check during due diligence, see Treelife’s guide on investor due diligence readiness for founders.

Q: Are Section 8 (non-profit) companies required to file DPT-3?
A: Yes. Section 8 companies are registered under the Companies Act 2013 and are not government companies. The filing obligation applies.

Q: Is there a filing extension for FY 2025-26?
A: No extension has been notified for FY 2025-26 as on the date of this publication. The MCA has in prior years issued extensions in specific circumstances, typically communicated via General Circulars. Monitor the MCA circulars page at mca.gov.in for any notification before assuming an extension applies.

Compliance checklist: Form DPT-3 for FY 2025-26

Before you file, confirm the following:

• Balance sheet as on 31 March 2026 finalised and audited (or at minimum, figures agreed with auditor)
• All outstanding amounts classified: deposit vs. non-deposit (Rule 2(1)(c) clause referenced for each exempted amount)
• Director loan declarations obtained from each director who has lent money to the company
• Customer advance ageing reviewed; amounts beyond 365 days flagged for reclassification review
• Net worth computation verified against audited balance sheet
• Field 3 purpose selected correctly (most private companies and startups: “Particulars of transactions not considered as deposit”)
• Field 15 table completed with opening balance, additions, repayments, adjustments, closing balance, and ageing for every applicable category
• Auditor’s certificate prepared, reviewed, and signed by the statutory auditor
• Board resolution authorising the signatory obtained
• DSC of authorised signatory and statutory auditor valid and registered on MCA portal
• Filing fee calculated based on paid-up share capital
• Filed on or before 30 June 2026; SRN saved

Regulatory references:

• Section 73, 76, 76A, Companies Act, 2013
• Section 448, 449, Companies Act, 2013 (false statement and false evidence)
• Rule 2(1)(c), Companies (Acceptance of Deposits) Rules, 2014 (definition and exclusions)
• Rule 16, Companies (Acceptance of Deposits) Rules, 2014 (return of deposits)
• Rule 16A, Companies (Acceptance of Deposits) Rules, 2014 (return of receipt of money not considered as deposit)
• Rule 21, Companies (Acceptance of Deposits) Rules, 2014 (punishment for contravention)
• MCA Notification dated 22 January 2019 (insertion of Rule 16A sub-rule 3)
• General Circular No. 05/2019 (extension of DPT-3 due date)
• Companies (Registration Offices and Fees) Rules, 2014 (filing fee schedule)

External sources:

• MCA e-filing portal: efiling.mca.gov.in
• MCA DPT-3 form page: https://www.mca.gov.in/content/mca/global/en/mca/e-filing/foreigncompany-deposits-and-Nidhi-services/DPT-3.html
• MCA circulars: https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html