Private Limited Company Post-Incorporation Compliance: First 180 Days and Year-One Calendar

Last updated 26 September 2026

What must a Private Limited company do right after incorporation?

After the Certificate of Incorporation arrives, a new Private Limited company has three early deadlines: 30 days for the first board meeting and first auditor, and 180 days for the INC-20A declaration that business can commence. Say Neha's company is incorporated on 1 October 2026. Her first board meeting and auditor appointment fall due around 31 October 2026, and INC-20A around the end of March 2027; her CA confirms the exact dates.

Incorporation itself is only the start. The Certificate of Incorporation gives the company a CIN (Corporate Identification Number), and with it come PAN and TAN, and the first set of statutory duties. A company that ignores them can attract penalties, and the ROC (Registrar of Companies) can even strike it off.

Your first-year checklist at a glance

1. Open the company bank account and bring in the subscribers' share capital.
2. Hold the first board meeting within 30 days.
3. Appoint the first auditor within 30 days and file ADT-1.
4. Set up statutory registers and issue share certificates.
5. File INC-20A within 180 days.
6. Hold the AGM, then file AOC-4 and MGT-7.

Shunya's Private Limited registration covers incorporation only. If you want help with post-incorporation filings, ask on the free callback.

How do you open the bank account and bring in share capital?

You open a current account in the company's name using the Certificate of Incorporation, PAN and the board's authorisation, and the subscribers then pay for their shares into it. There is no minimum paid-up capital, but the subscribers must actually pay for the shares they agreed to take in the Memorandum, because INC-20A later declares exactly that.

Bank account opening is triggered at incorporation through AGILE-PRO-S, the linked form filed with SPICe+ (Simplified Proforma for Incorporating Company Electronically Plus). At present, the form carries the bank account request, but opening is completed only after the bank's own KYC (know your customer) checks, so expect the bank to call for documents and a visit or video verification.

Keep clean records from day one

• Pay share money from the subscriber's own bank account into the company account, not in cash.
• Keep the bank statement showing the credits; you will need it for INC-20A.
• Do not use the company account for personal expenses. Directors' loans and advances must be documented.

GST registration is optional at incorporation and depends on your turnover and type of supply. It is compulsory regardless of turnover in some cases, such as inter-state supply of goods and e-commerce selling. Our GST registration page covers when it applies.

What is INC-20A and what is the penalty for missing it?

INC-20A is the declaration, required under section 10A of the Companies Act, 2013, that every subscriber has paid for the shares agreed to be taken and that the registered office has been verified. It must be filed within 180 days of incorporation, and the company should not commence business or exercise borrowing powers until it is done.

The penalty is heavy relative to the effort: ₹50,000 on the company, plus ₹1,000 per day on each officer in default while the default continues, with the ROC also empowered to strike the company off. Late-filing additional fees may also apply. Treat 180 days as a hard limit and file it early, rather than at the end of the window.

What you need to file INC-20A

• A director's declaration that subscribers have paid for their shares.
• Bank proof of the share money received.
• Proof that the registered office is verified. If the address filed in SPICe+ is the registered office, INC-22 is not needed. Otherwise, INC-22 must be filed within 30 days of incorporation.

For office proof rules, our registered office requirements guide explains what documents work. MCA V3 now asks for the latitude and longitude of the registered office, so keep the coordinates handy.

What happens at the first board meeting and first auditor appointment?

The first board meeting must be held within 30 days of incorporation, and the Board must appoint the first auditor within the same 30 days under section 139(6). If the Board misses this, the members can appoint the first auditor at an extraordinary general meeting within 90 days of incorporation. The first auditor holds office until the first AGM.

A statutory audit is mandatory every year for every Private Limited company, whatever its turnover. That is a real running cost for startups, so budget for it. After the appointment, file Form ADT-1 with the ROC within 15 days of the appointment. Vendors and professionals differ on whether ADT-1 is strictly mandatory for a Board-appointed first auditor, but filing it is the standard practice and the safer course.

Agenda for the first board meeting

• Take note of the Certificate of Incorporation and the Memorandum and Articles.
• Appoint the first auditor and fix how the audit will be arranged.
• Approve the registered office and the company's bank account and signatories.
• Take on record directors' disclosures of interest.
• Authorise share certificates and the statutory registers.

Record everything in minutes, signed by the chairperson. Statutory registers, such as the register of members and the register of directors, need to be maintained from the start. Share certificate timelines are set in the Companies Act, so ask your CA for the exact date that applies to your subscribers.

How does DIR-3 KYC work for directors now?

From 31 March 2026, directors file DIR-3 KYC once every three financial years instead of every year, and the due date is 30 June. The change came through an MCA notification dated 31 December 2025 amending the director qualification rules, and it applies to the web form only. A director who misses it has the DIN (Director Identification Number) deactivated, and reactivation carries a fee of ₹5,000.

Changes in mobile number, email or address must be reported within 30 days. Directors whose KYC was completed up to FY 2025-26 are next due on 30 June 2028. Some vendor pages still describe the old 30 September annual cycle, and a few say 30 September 2026 applies to certain older DINs, so do not rely on a blog post. Ask your CA what applies to each director's DIN, including when a newly allotted DIN's first KYC falls due.

• Keep each director's mobile number and email active, since OTPs are sent there.
• Report contact changes within 30 days, not at the next KYC.
• Check that the DIN status shows as approved before signing filings.

What are the annual filings and due dates in year one?

The annual cycle for a Private Limited company runs around the AGM: AOC-4 (financial statements) is due within 30 days of the AGM and MGT-7 (annual return) within 60 days of the AGM. For a financial year ending 31 March, the AGM is due within six months, meaning by 30 September in regular cases. The first AGM has its own timing, so confirm it with your CA.

Late AOC-4 or MGT-7 attracts an additional fee of ₹100 per day per form, with no cap. Other ROC forms carry additional fees that rise with the length of delay. Income tax returns, tax audit and GST returns have their own dates, so ask your CA for those separately.

Are any of these rules changing, and who should handle them?

Some proposals are pending, but none of them is law yet as of September 2026, so plan on the current rules. The Corporate Laws (Amendment) Bill, 2026 is still before Parliament after its Joint Parliamentary Committee report, and the MCA's April 2026 draft incorporation rules have not been notified as final. Both float ideas such as simpler small-company rules and fewer board meetings, but you cannot rely on them.

Please treat blogs that describe those ideas as current rules with caution. Missing a statutory date costs real money, and a wrong assumption is costly.

Shunya's ₹1,999 covers incorporation: CA verification, name check, DSC and DIN, MOA and AOA, SPICe+ with AGILE-PRO-S for PAN and TAN, ROC queries and the Certificate of Incorporation. Ongoing filings such as INC-20A, ADT-1, AOC-4 and MGT-7 are not part of that fee. Ask on the free callback whether they can be arranged, and at what cost, so you are not surprised later. For what comes before this stage, see the registration process and timeline guide. If you run a startup, this startup guide covers what investors look for in your records.

This article is for general information only. For your specific situation, consult a practicing CA.