Form DPT-3: Applicability, Due Date and Filing Guide (2026) | TargoLegal Blog

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MCA deposit and non-deposit reporting

Form DPT-3: Applicability, Due Date and Filing Guide (2026)

A company-law guide that corrects the supplied draft's 30 May deadline, nil-return claim and overbroad statements about NBFCs and deposit-taking companies.

India-specific scope30 June deadline corrected
Primary law checkedNil-return myth removed
Decision-focusedDeposit and exempt amount mapping added
Practical answer

The short answer

Form DPT-3 is generally an annual company filing for outstanding deposits and amounts not treated as deposits as at 31 March. Under Rules 16 and 16A, the annual return is due by 30 June. It is not a universal nil return for every company, and regulated banking companies, NBFCs registered with RBI, housing finance companies and specified government companies require exemption and scope analysis before filing.

Decision framework

Start with purpose, evidence and consequence

The correct answer depends on what the business or right must achieve, who controls it, which authority governs it, and what happens if the assumption is wrong. Record the facts first; then test the governing law and current official process.

Do not preserve a convenient statement from an older article when the statute, portal, form or commercial facts point elsewhere. The sections below correct oversimplifications in the supplied draft and add the checks a founder should perform before acting.

01 · Core analysis

Why DPT-3 exists

The Companies (Acceptance of Deposits) Rules use DPT-3 to report deposits and outstanding money or loans that fall within exclusions from the statutory definition of deposit. It is a classification and balance exercise, not merely a list of public deposits.

Start with the ledger as at 31 March and classify each credit balance by counterparty, instrument, purpose, terms, ageing, allotment or repayment status and the exact Rule 2(1)(c) exclusion relied on.

02 · Core analysis

Who must file—and who may be exempt

Companies with relevant outstanding deposits, secured or unsecured loans, or money not treated as deposits generally assess annual filing. Private-company status does not by itself remove the requirement.

Banking companies, NBFCs registered with RBI, housing finance companies and other excluded categories should be tested against the Rules. LLPs and ordinary partnership firms do not file company Form DPT-3. Do not submit a nil return without confirming applicability and live MCA form logic.

START WITH THE FACTSowners · activity · risk · funding LOWER COMPLEXITYstandard facts · documented path HIGHER COMPLEXITYspecial rights · regulated facts VERIFY AND DOCUMENTOBTAIN SPECIALIST REVIEW
Figure 2. Start with the facts, then match complexity and consequence to the right level of review.
03 · Core analysis

Due date and reporting period

The annual DPT-3 return reports the position on 31 March and is due by 30 June each year under the Rules, unless MCA issues a specific extension. For the position as at 31 March 2026, plan filing by 30 June 2026.

The historic one-time return introduced in 2019 should not be confused with the recurring annual return. Maintain an internal close timetable well before June.

04 · Core analysis

Prepare the classification workbook

Reconcile trial balance, audited or provisional financial statements, bank statements, loan agreements, shareholder and director ledgers, advances, debentures, inter-corporate borrowings, customer advances and securities application money.

For every exclusion, record the rule clause, facts, counterparty evidence, agreement, receipt and outstanding balance. Ageing matters: an amount initially excluded may become non-compliant if conditions or timelines cease to be met.

VERIFY EXPOSUREhigh consequence · clearer ruleSPECIALIST REVIEWhigh consequence · disputed factsSTANDARD CHECKlower consequence · clear evidenceBUILD EVIDENCElower consequence · weak recordsEVIDENCE COMPLEXITY →LEGAL / COMMERCIAL CONSEQUENCE →
Figure 3. Evidence quality and potential consequence determine when a standard check is insufficient.
05 · Core analysis

Complete and certify the filing

Use the current MCA webform and instruction kit. Confirm company master data, purpose of return, net worth or financial particulars, deposit and non-deposit totals, charge information and attachments requested by the live form.

Obtain the auditor's certificate where required by the selected return purpose and current instructions. The authorised signatory must use a valid DSC; professional certification applies where the form requires it. Retain SRN, challan, signed form and final workbook.

06 · Core analysis

Consequences and remediation

Late or inaccurate filing can attract additional filing fees and action under the Companies Act and deposit rules. Penalties depend on the exact breach; deposit-acceptance violations are not interchangeable with a simple late-form default.

If the ledger reveals an impermissible deposit, delayed allotment, missing agreement or repayment default, do not disguise it through classification. Escalate for a remediation and disclosure plan before certification.

Side-by-side

Comparison that works on mobile

Issue
Option AIncorrect shortcut
Option BCurrent control
Reporting date
Option ATransactions during the year only
Option BOutstanding position as at 31 March
Due date
Option A30 May
Option B30 June, subject to notified extension
Nil balance
Option AEvery company files a nil return
Option BApplicability depends on reportable outstanding amounts and exemptions
Auditor certificate
Option AAlways required
Option BDepends on return purpose and live form instructions
Avoidable errors

Common mistakes

  • Using 30 May as the annual deadline
  • Treating every credit balance as a deposit
  • Assuming every company must file nil DPT-3
  • Copying prior-year classifications without ageing review
  • Quoting one penalty section for every default
Boundary

When this guide does not decide the answer

Public deposits, repayment default, debentures, group treasury arrangements, foreign money, share application ageing, acquisition balances or prior incorrect filings need company-secretarial and accounting review.

Implementation

A four-stage action plan

01 · DEFINEfacts and goal02 · VERIFYlaw and scope03 · RECORDdocuments andapprovals04 · REVIEWfile, monitor, renewA control sequence—not a government processing-time promise
Figure 4. Define the facts, verify the law, preserve evidence and review ongoing obligations.

Define: write the parties, activity, territory, asset, funding and intended outcome. Verify: open the current official law, form and authority guidance. Record: prepare approvals, agreements, evidence and a compliance calendar. Review: file through the correct channel, retain acknowledgements and monitor renewals or changes.

Get the structure and filings reviewed

TargoLegal can review the facts, map the governing registrations or documents, and identify the recurring compliance that follows the initial decision.

Request a structured consultation
Common questions

Frequently asked questions

What is the shortest practical answer on Form DPT-3?

Form DPT-3 is generally an annual company filing for outstanding deposits and amounts not treated as deposits as at 31 March. Under Rules 16 and 16A, the annual return is due by 30 June. It is not a universal nil return for every company, and regulated banking companies, NBFCs registered with RBI, housing finance companies and specified government companies require exemption and scope analysis before filing.

Is the lower-cost option automatically better?

No. Compare liability, control, taxation, recurring compliance, funding, contracts, exit and the cost of changing later. Formation price alone is not a reliable decision rule.

Can I change the structure or protection route later?

Often yes, but a later change may require approvals, tax and stamp analysis, contract or licence migration, fresh filings and third-party consent. Plan the likely next stage before committing.

Which documents should I keep?

Keep the governing instrument, approvals, filings, invoices, resolutions, contracts, ownership records, use evidence and authority acknowledgements that support the position taken.

When should I obtain professional advice?

Use a qualified legal, tax or regulatory professional when the transaction is high-value, disputed, regulated, cross-border, investor-funded, property-backed or capable of creating personal liability.

How current is this guide?

The legal and official-source review was completed on 2026-07-27. Rules, portals, forms and State practice can change, so recheck the linked official source before filing or acting.

Current research
  1. India Code — Companies Act, 2013
  2. MCA — Companies (Acceptance of Deposits) Rules resources
  3. Ministry of Corporate Affairs
  4. TargoLegal company compliance support
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