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ROC & Corporate Compliance / Annual ROC Compliance

DPT-3 Return of Deposits and Outstanding Loans

Prepare and file Form DPT-3 to report deposits and outstanding loans or receipts that are not deposits, with the schedule and auditor certificate lined up before the 30 June date.

Overview

Form DPT-3 is the return a company files with the Registrar of Companies to report deposits it holds and also money or loans it has received that are not treated as deposits. It comes from the Companies (Acceptance of Deposits) Rules, 2014, notably Rule 16 and Rule 16A. Since an amendment notified in January 2019, most companies must file it every year, even when they hold no deposits, if they have outstanding loans or similar receipts.

Who needs it

  • Companies, other than government companies, with outstanding loans or receipts that are not deposits, such as loans from directors, shareholders or related companies.
  • Companies that have accepted deposits from members or the public.
  • Private limited companies, OPCs, small companies and public companies alike.
  • Companies catching up on earlier returns.

Banks, NBFCs, housing finance companies and government companies are exempt, as are other companies notified by the MCA.

What Zenith does

Zenith listens first to how the company is funded and what it owes, then clarifies scope and quotes. A relationship manager is assigned and a checklist is shared.

  • Review the ledgers for loans, advances and deposits to classify each as a deposit or as an exempt receipt.
  • Build the schedule of amounts outstanding at 31 March and tie it to the audited balance sheet.
  • Coordinate the auditor's certificate where required, through an authorised professional.
  • Prepare, sign and file DPT-3, track the SRN and handle queries.
  • Explain what was reported and what to maintain for next year.

Eligibility and key rules

  • Annual return: due by 30 June for the position as of 31 March. Extensions have been announced in some years, so the current date is verified.
  • One-time return: the January 2019 amendment also required a return of outstanding non-deposit receipts for the period 1 April 2014 to 31 March 2019, which companies still reconcile for older records.
  • What is not a deposit includes share capital, debentures, bank and financial institution loans, inter-company loans, advances against orders, subscription advances, and security deposits from employees up to their annual salary.
  • Loans from holding, subsidiary or associate companies are reported.
  • Secured and unsecured borrowings and advances for goods or services are within scope.
  • A company with no outstanding such receipts at 31 March may have nothing to report, which is confirmed against the ledgers.

Documents required

  • Audited financial statements and a schedule of loans, deposits and advances.
  • Auditor's certificate on the DPT-3 data.
  • Details of lenders, amounts, dates, and the nature of each receipt.
  • Net worth and credit rating details where applicable.
  • Trust deed, if deposits are held in a trust, and the charge instrument if the deposits are secured.
  • List of depositors, where deposits exist.
  • CIN, company email, objects, and digital signature certificate of the signing director.

Process and timeline

  1. Collect ledgers and lender confirmations for the year.
  2. Classify each amount, and prepare the outstanding schedule.
  3. Get the auditor's certificate.
  4. Prepare DPT-3 on the MCA21 portal with the details above.
  5. Sign with a DSC, pay the fee and submit; an SRN is generated.
  6. An acknowledgement is emailed after processing.

Timelines depend on completeness, complexity and authority processing.

Government fees, penalties and due dates

The ROC fee depends on share capital: ₹200 below ₹1 lakh, ₹300 to below ₹5 lakh, ₹400 to below ₹25 lakh, ₹500 to below ₹1 crore and ₹600 above.

  • Late fee: sources describe 2 to 12 times the normal fee depending on days of delay.
  • Default: the company and each officer in default can face a fine that may extend to ₹5,000, plus up to ₹500 a day for continuing default, per sources read.
  • Larger penalties apply separately to accepting deposits in breach of the Act.
  • Due date: 30 June each year for 31 March data, subject to notified extensions.

Amounts and dates above reflect public sources read in October 2026 and change with notifications, so Zenith confirms the current figures in your quotation.

Common mistakes

  • Assuming that a company without public deposits has nothing to file.
  • Treating director or shareholder loans as share capital without the declaration.
  • Not obtaining the auditor's certificate before filing.
  • Reporting figures that do not match the audited balance sheet.
  • Forgetting loans from holding or associate companies.
  • Missing the 30 June date while waiting for audited accounts.

FAQs

Who must file DPT-3?

Companies other than government companies with outstanding deposits or non-deposit receipts.

When is it due?

30 June for the previous 31 March position, unless extended.

Is an auditor's certificate needed?

Yes, the return carries one.

Are bank loans reported?

Loans from banks and financial institutions are not treated as deposits, though they are reviewed during classification.

Does a company with no loans need to file?

It depends on what is outstanding at 31 March; the professional confirms from the ledgers.

What is the penalty?

A fine on the company and officers, with a daily amount for continuing default.

Can past years be filed late?

Yes, with additional fees for each delayed return.