MCA notification May 2026: New disclosure rules for startups and what changes
· KAMRIT MCA Desk
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The Ministry of Corporate Affairs published a notification this month that tightens disclosure requirements for DPIIT-recognised startups and small companies. The change is incremental but the operational impact on AOC-4 and MGT-7 filings is real. KAMRIT clients filing in the next two quarters need to plan for the additional disclosures.
What the notification changes
The notification introduces an additional schedule to AOC-4 covering related-party balances, ESOP grants in the year, and any non-cash compensation. Small companies that have historically filed AOC-4 with limited disclosures will need to provide the same level of detail as larger companies, with effect from the next filing cycle.
Who is affected
DPIIT-recognised startups, all small companies (paid-up capital under ₹4 crore and turnover under ₹40 crore), and Section 8 companies. OPCs are exempt from the new schedule, but they are still required to file the standard AOC-4.
Operational impact
Most startups will need to maintain a contemporaneous register of related-party balances and ESOP grants. KAMRIT clients on monthly compliance retainers will see the additional schedule baked into the close pack starting next month. For one-off AOC-4 engagements, expect to spend an additional two days collecting the underlying data.
Penalty for non-compliance
Late or incomplete AOC-4 filings continue to attract ₹100 per day per form with no maximum cap. The new schedule is not a separate form, but an incomplete AOC-4 will be treated as a defective filing and resubmission will be required.
What to do
Update your books to track related-party balances by quarter. Maintain an ESOP grant register with grant date, exercise price, and vesting schedule. Confirm with KAMRIT whether your monthly retainer covers the new schedule (it does for clients on the standard MCA package).
Talk to a senior expert
If this affects your business, send a quick brief to KAMRIT. A senior partner replies within one business day with a written view and a fixed-fee quote if remediation work is required. Browse the full MCA services catalogue for related capabilities.