DPT-3 filing: what it is, who must file, and the 30 June deadline
DPT-3 filing is the annual return of deposits, and of money received that the rules do not treat as a deposit, made by every company other than a Government company under Rule 16 of the Companies (Acceptance of Deposits) Rules 2014. It is due on or before 30 June each year for the amounts outstanding on 31 March, audited by the company’s auditor. For FY 2025-26 the date was 30 June 2026, with additional fees waived to 31 July 2026; for FY 2026-27 it is 30 June 2027.
What DPT-3 is, and the one-time return it is confused with
Rule 16 of the Companies (Acceptance of Deposits) Rules 2014 requires every company to which the rules apply, other than a Government company, to file a return in Form DPT-3 with the Registrar on or before 30 June every year, giving the information as on 31 March, duly audited by the company’s auditor; since 29 August 2022 (G.S.R. 663(E)) the auditor also gives a declaration in the form. Under the Explanation to Rule 16, the form is used for a return of deposits, or for particulars of transactions not considered as deposits, or both. DPT-3 is a return of loans as much as of deposits.
The one-time versus annual confusion comes from Rule 16A(3), inserted on 22 January 2019, which required a one-time return, also in Form DPT-3, of money or loans not treated as deposits outstanding from 1 April 2014 to 31 March 2019, due within ninety days of that date. That window has closed, though the eForm still lists it among its purposes. Rule 16A(2) separately requires a private company to disclose money received from directors or their relatives in the notes to its financial statements (Rule 16A(1) is the equivalent for other companies, covering directors only), and that note, the Board’s report and the DPT-3 line should agree.
Who must file DPT-3
Every company to which the rules apply, except a Government company (section 2(45) of the Companies Act 2013: at least 51 per cent of the paid-up share capital held by the Central or a State Government). The rules do not apply to a banking company, an RBI-registered non-banking financial company, a housing finance company registered with the National Housing Bank, or a company the Central Government specifies under section 73. A private limited company and an Indian subsidiary of a foreign parent are both inside.
Rule 16 has no nil-return carve-out: a startup with a founder loan, a foreign-parent advance, CCDs or a customer advance outstanding on 31 March has something to report with zero deposits, and the rules say nothing express about a company with nothing outstanding in either column. Section 2(31) of the Act treats any receipt of money by way of deposit or loan or in any other form as a deposit except the categories Rule 2(1)(c) lists; Schedule A maps the ones a startup usually holds.
Schedule A: how common startup receipts are treated
| Receipt | Rule 2(1)(c) position | Conditions that hold the exclusion | Where it lands in DPT-3 |
|---|---|---|---|
| Founder or director loan; loan from a director’s relative (private company) | Not a deposit, sub-clause (viii), if the lender was a director at the time of receipt, or a relative of a director where the company is private | Lender’s written declaration that the money is not borrowed funds; Board’s report disclosure; Rule 16A note in the accounts | Exempt-deposit particulars, at the amount outstanding on 31 March |
| Loan or advance from a foreign parent or foreign investor | Not a deposit, sub-clause (ii) | Must comply with the Foreign Exchange Management Act 1999; that leg runs on the FEMA and FDI compliance checklist | Exempt-deposit particulars |
| Compulsorily convertible debenture (CCD) | Not a deposit, sub-clause (ix) | Compulsorily convertible into shares within ten years; the instrument is compared on SAFE vs CCD vs priced round | Exempt-deposit particulars |
| Start-up convertible note | Not a deposit, sub-clause (xvii) | Rs 25 lakh or more in a single tranche; issuer is a DPIIT-recognised private company; convertible or repayable within ten years of issue | Exempt-deposit particulars. A smaller note, or one from a company without DPIIT recognition, falls outside (xvii) |
| Share application money | Not a deposit, sub-clause (vii), while appropriated only against allotment | Allot within 60 days of receipt; if not, refund within 15 days after that, or the amount is treated as a deposit | Exempt-deposit particulars while within time; deposit column once the clock has run |
| Customer advances and prepayments | Not a deposit, sub-clause (xii) | Appropriated against goods or services within 365 days of acceptance | Exempt-deposit particulars; beyond 365 days the advance can fall back into the deposit definition |
| Money accepted from members under the private company relaxation | A deposit; section 73(2) clauses (a) to (e) relaxed by MCA notifications of 5 June 2015 and 13 June 2017 | Within 100 per cent of paid-up capital, free reserves and securities premium, or a start-up within five years of incorporation, or the borrowing test; details filed with the Registrar | Return of deposit, with the auditor’s certificate attached |
Sub-clauses are those of Rule 2(1)(c) as amended up to G.S.R. 663(E) of 29 August 2022. Also excluded: bank, public financial institution, insurance company and scheduled bank loans (iii, iv), commercial paper (vi), an employee security deposit within annual salary (xi), and promoter loans on a lender’s stipulation (xiii).
The 30 June due date: FY 2025-26 and FY 2026-27
The statutory date does not move: Rule 16 fixes 30 June of every year for the information as on 31 March. What moves, occasionally, is the additional-fee clock, by one-off MCA General Circular, as a circular of 21 June 2023 did for the previous year, to 31 July 2023.
For FY 2025-26, MCA General Circular No. 02/2026 dated 19 June 2026 allowed DPT-3 to be filed without additional fees up to 31 July 2026, after a fire incident at the MCA data centre on 5 June 2026. As at 18 September 2026 both dates have passed, so an FY 2025-26 return still unfiled is late, carries additional fees and sits within Rule 21. The circular is cited here by number and date.
For FY 2026-27, the return reports amounts outstanding on 31 March 2027 and is due on or before 30 June 2027, unless MCA issues a further circular. It sits with the FLA return (15 July) and DIR-3 KYC (30 September) on the India compliance calendar for FY 2026-27.
How to file DPT-3: the sequence
The return is filed electronically with the Registrar on the MCA portal; the work that decides whether it is right happens before the form is opened.
- Freeze the 31 March balances. List every receipt of money outstanding at year end that is not share capital or a trade payable; the return is about what is outstanding, not what came in during the year.
- Classify each receipt against Rule 2(1)(c). Use Schedule A and test each exclusion’s conditions. Anything that fails moves to the deposit column and raises a section 73 question bigger than the form.
- Gather the paper the exclusions depend on. Director and relative declarations, the Board’s report disclosure, the Rule 16A note, and the FEMA filings for foreign receipts.
- Have the auditor audit the figures and give the declaration. Rule 16 requires both. The separate auditor’s certificate attachment is mandatory only where the purpose includes a return of deposits.
- Pass the board resolution and complete the form. Select the purpose, enter net worth per the latest audited balance sheet, enter the exempt-deposit amounts category by category (zero where none applies) and attach what the purpose requires.
- Sign, pay and file by 30 June. A director, manager, CEO, CFO or company secretary signs with a registered digital signature; a disqualified director cannot. The normal fee is Rs 200 to Rs 600 by nominal share capital under the Companies (Registration Offices and Fees) Rules 2014, as read on 18 September 2026.
Penalty for late filing of DPT-3
A late return costs two layers; a third exposure belongs to a different failure. First, the additional fee under the Companies (Registration Offices and Fees) Rules 2014: two times the normal fee for a delay of more than 15 and up to 30 days, four times up to 60 days, six times up to 90 days, ten times up to 180 days and twelve times beyond that; the higher column applies only to repeat delays in INC-22 and PAS-3. On a normal fee of Rs 200 to Rs 600 the money is small; the record of a late filing is what diligence notices.
Second, Rule 21 of the Deposits Rules: for a contravention the Act does not otherwise punish, the company and every officer in default face a fine of up to Rs 5,000 and up to Rs 500 for every further day. A missed or late DPT-3 falls here.
A third figure is often confused with the late-filing penalty and does not belong there. Section 76A punishes accepting deposits in contravention of section 73 or 76, or failing to repay them: repayment with interest, a company fine of not less than Rs 1 crore or twice the deposit (whichever is lower) up to Rs 10 crore, and for every officer in default imprisonment of up to seven years and a fine of Rs 25 lakh to Rs 2 crore. That is the exposure when a deposit was booked as something else, which is why step two matters more than the date.
Who signs what on a DPT-3 filing
The statute names the signatories and they stay as named: a director, manager, CEO, CFO or company secretary of the company signs the eForm under a board resolution, and the audit declaration comes from the company’s statutory auditor, a chartered accountant, whom Rule 16 names. Infinilex counsel qualified in India (an advocate enrolled in India, with Infinilex’s company secretary) classify each receipt against Rule 2(1)(c), assemble the declarations and disclosures, draft the board resolution and prepare the return for the company’s signatory and auditor; on the fractional general counsel retainer this runs inside the annual calendar. Where a receipt has a FEMA leg, the RBI filings stay with the company and the AD bank, as on FEMA, ODI and LRS compliance.
Frequently asked questions
What is DPT-3 filing and when is it due?
DPT-3 is the return every company other than a Government company files with the Registrar under Rule 16 of the Companies (Acceptance of Deposits) Rules 2014. It reports deposits, and money or loans received that the rules do not treat as deposits, outstanding on 31 March, audited by the company's auditor. The statutory due date is 30 June every year: 30 June 2026 for FY 2025-26, with additional fees waived to 31 July 2026 by MCA General Circular 02/2026, and 30 June 2027 for FY 2026-27.
Is DPT-3 required if the company has no deposits?
Having no deposits does not by itself take a company outside Rule 16, because the form is not only a return of deposits. The Explanation to Rule 16 says DPT-3 also carries particulars of transactions not considered as deposits. A startup with a founder loan, a CCD, a foreign-parent advance or an old customer advance outstanding on 31 March has exempt-deposit particulars to report. The rules contain no express exemption for a company with nothing outstanding in either column; settle that position with the auditor and record it.
Are convertible notes and CCDs reported in DPT-3?
Yes, as transactions not considered deposits, provided the exclusion's conditions are met. Debentures compulsorily convertible into shares within ten years fall under Rule 2(1)(c)(ix). A convertible note of Rs 25 lakh or more in a single tranche, issued by a DPIIT-recognised start-up and convertible or repayable within ten years, falls under Rule 2(1)(c)(xvii). Both are reported at the amount outstanding on 31 March. A note below Rs 25 lakh, or one issued without DPIIT recognition, does not fit (xvii) and needs its own analysis.
What is the penalty for late filing of DPT-3?
Two layers. First, the additional filing fee under the Companies (Registration Offices and Fees) Rules 2014: two times the normal fee of Rs 200 to Rs 600 for a delay of more than 15 and up to 30 days, rising through four, six and ten times to twelve times beyond 180 days. Second, Rule 21 of the Deposits Rules: up to Rs 5,000 on the company and every officer in default, plus up to Rs 500 a day of continuing default. Section 76A's heavier penalties apply to accepting an unlawful deposit, not to a late return.
Is DPT-3 a one-time return or an annual return?
Both existed; only the annual one is live. Rule 16A(3), inserted in January 2019, required a one-time return of money or loans received between 1 April 2014 and 31 March 2019 that were not treated as deposits, due within 90 days of 31 March 2019; that window has closed. Rule 16 is the standing obligation: a return every year, on or before 30 June, for amounts outstanding on 31 March, on the same eForm DPT-3, which still lists the one-time return among its purposes.
Not sure which column a receipt belongs in?
Send us what the company held on 31 March that was not share capital. We will map each item to its sub-clause, flag anything that has become a deposit, and set up the return for your auditor and signatory.
Further reading
India compliance calendar FY 2026-27 · Fractional general counsel retainer · SAFE vs CCD vs priced round · Convertible notes from foreign investors into India · FEMA and FDI compliance checklist · India subsidiary setup
This article is general information for founders, not legal advice on your company’s receipts. The rules (as amended up to G.S.R. 663(E) of 29 August 2022), the Companies Act 2013 provisions, the fee tables and MCA General Circular 02/2026 are stated as read on 18 September 2026 and re-verified quarterly. Whether a receipt meets an exclusion depends on its documents; confirm the position with your auditor before the return is signed.