DPT-3 Return of Deposits 2026 for Foreign Owned Companies in India

Written by CA Nandini, Krystal7 Consultants. Last updated 27 September 2026.

Form DPT-3 is the annual return of deposits under rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. Every company other than a government company files it by 30 June, with figures as on 31 March. For FY 2025-26, MCA General Circular No. 02/2026 of 19 Jun 2026 allowed filing without additional fees up to 31 Jul 2026. A foreign owned subsidiary with no deposits still reports its parent loans, director loans and other exempt receipts.

This page covers what a foreign owned Indian company reports in DPT-3 and when an exempt receipt turns into a deposit. Rupee amounts use Indian grouping: INR 1,00,000 is one lakh (100,000), and INR 1,00,00,000 is one crore (10 million).

What is Form DPT-3?

Form DPT-3 is the return of deposits a company files with the Registrar of Companies (ROC) on the MCA V3 portal. Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014 (the Deposit Rules) requires it. It reports, as on 31 March, the deposits a company holds and the receipts the rules do not treat as deposits.

Section 2(31) of the Companies Act, 2013 defines a deposit, and section 73 limits who may accept one. Rule 2(1)(c) of the Deposit Rules lists the exclusions. The Explanation to rule 16 gives the form three purposes: a return of deposits, particulars of transactions not considered deposits, or both. The MCA V3 instruction kit for DPT-3 shows these as radio buttons, and you pick one per filing. The kit also keeps a fourth option for the one time return of 2019.

Two amendments shaped today's form. The 2019 amendments added rule 16A, which asked for a one time return of exempt receipts outstanding from 1 Apr 2014 to 31 Mar 2019. The Companies (Acceptance of Deposits) Amendment Rules, 2022 (G.S.R. 663(E), 29 Aug 2022) replaced Form DPT-3 and wrote the auditor's declaration into rule 16.

Item	Position on 27 Sep 2026
Legal basis	Sections 2(31) and 73 of the Companies Act, 2013; rules 2(1)(c), 16 and 16A of the Deposit Rules
Who files	Every company other than a government company, except banking companies, RBI registered NBFCs and housing finance companies
Reporting date	31 March each year
Statutory due date	30 June of the same year
FY 2025-26 relief	No additional fees up to 31 Jul 2026 (General Circular No. 02/2026)
Purposes	Return of deposits; particulars of amounts not considered deposits; both
Auditor's declaration	Needed when the return reports deposits
Processing	MCA V3 web form; straight through processing for an exempt only return, ROC review when deposits are reported
Normal fee (INR)	200 to 600, by nominal share capital
Additional fee for delay	2 to 12 times the normal fee
Penalty for default (INR)	Section 450: 10,000 plus 1,000 a day, capped at 2,00,000 for the company and 50,000 per officer

Who must file DPT-3?

Every company other than a government company files DPT-3 if, on 31 March, it holds a deposit or an outstanding exempt receipt. That covers private companies, one person companies, small companies and Section 8 companies. Rule 1(3) keeps banking companies, NBFCs registered with the Reserve Bank of India (RBI) and housing finance companies outside the Deposit Rules.

A foreign company's branch, liaison or project office does not file DPT-3. Section 2(20) of the Act limits "company" to companies formed under Indian company law. A limited liability partnership has no DPT-3 either.

The rules do not mention a nil return, and we read rule 16 as not needing one. A company with no deposit and no exempt receipt outstanding on 31 March has nothing to report. That is rare for a foreign owned subsidiary. Most carry at least one of these balances:

• a loan or advance from the foreign parent;
• share application money sent ahead of an allotment;
• advances or security deposits from Indian customers;
• a loan from a director or an Indian group company;
• a bank working capital line.

For the rare year with nothing to report, we keep a short board note so the file shows the decision. The full annual calendar is in our foreign subsidiary compliance guide.

What is the DPT-3 due date for 2026?

The statutory due date for the return as on 31 Mar 2026 was 30 Jun 2026, under rule 16, and it did not change. MCA General Circular No. 02/2026 of 19 Jun 2026 let companies file DPT-3 without additional fees up to 31 Jul 2026. MCA gave this relief after a fire at its data centre on 5 Jun 2026.

Several websites call this an extension of the due date to 31 Jul 2026. The practical effect is close, but the circular's words differ. Its first paragraph repeats that the due date for FY 2025-26 is 30 Jun 2026. It then cites restoration work at the MCA data centre after the fire. On that ground, it allows companies to file DPT-3 "without paying additional fees up to 31st July 2026". Rule 16 still says 30 June.

Three practical points follow:

1. A return filed on or before 31 Jul 2026 paid only the normal fee.
2. A return filed after 31 Jul 2026 pays the additional fee. The circular does not say whether the delay then counts from 30 Jun 2026 or from 31 Jul 2026. The V3 portal works out the fee when you file, so check the amount before you pay. The worked example below shows both cases.
3. The relief covers FY 2025-26 only. The return as on 31 Mar 2027 is due on 30 Jun 2027.

The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) does not help with DPT-3. General Circular No. 01/2026 of 24 Feb 2026 opened it from 15 Apr 2026 to 15 Jul 2026. Its form list covers annual filings such as AOC-4, MGT-7 and ADT-1, and leaves out DPT-3.

General Circular No. 03/2026 of 8 Jul 2026 extended CCFS-2026 to 31 Aug 2026. General Circular No. 04/2026 of 31 Aug 2026 then took it to 15 Sep 2026, with all other terms unchanged. We found no later extension.

Return as on	Statutory due date	MCA relaxation for DPT-3	Last date without additional fee
31 Mar 2024 (FY 2023-24)	30 Jun 2024	None found	30 Jun 2024
31 Mar 2025 (FY 2024-25)	30 Jun 2025	None found	30 Jun 2025
31 Mar 2026 (FY 2025-26)	30 Jun 2026	General Circular No. 02/2026, 19 Jun 2026	31 Jul 2026
31 Mar 2027 (FY 2026-27)	30 Jun 2027	Not yet known	30 Jun 2027

Add 30 Jun 2027 to your 2026-27 compliance calendar. We found no MCA circular that relaxed DPT-3 fees in 2024 or 2025. General Circular No. 01/2025 of 16 Jun 2025 relaxed additional fees for 13 forms while MCA moved them to MCA21 V3. We did not find DPT-3 in its list. If a 2025 filing is in question, check the annexure to that circular on the MCA circulars page.

What counts as a deposit under the Companies Act?

Section 2(31) of the Companies Act, 2013 defines a deposit widely. It covers any receipt of money by way of deposit or loan, or in any other form. Rule 2(1)(c) then excludes a long list of receipts. Money that fits no exclusion is a deposit, and section 73 controls who may accept it.

The test turns on money received. A trade payable to the parent for invoiced services is not a receipt of money. Neither is an accrued expense or a director's unpaid reimbursement. These stay out of DPT-3.

Section 73(2) lets a company accept deposits from its members, on conditions. Section 76 lets only an eligible public company take deposits from the public. MCA's exemption notification of 5 Jun 2015 (G.S.R. 464(E)), as amended on 13 Jun 2017, eases the member deposit conditions for private companies. Nothing lets a private company take a deposit from an outsider.

So when an exempt receipt loses its exemption, a foreign owned private company holds a deposit it had no power to accept. That breaches section 73, which section 76A punishes.

Which receipts are not deposits under rule 2(1)(c)?

Rule 2(1)(c) excludes 25 kinds of receipt across clauses (i) to (xviii), clause (ixa) and items (a) to (g) of clause (xii). A foreign owned subsidiary usually meets eight of them. They are foreign lenders (ii), banks (iii), other companies (vi), share money (vii), directors (viii), convertible debentures (ix), employees (x) and business advances (xii).

Each exclusion carries a condition, and a receipt that fails it becomes a deposit. The table paraphrases the rule as amended up to 2022.

Clause	Receipt excluded	Condition	Seen in a foreign owned subsidiary
(i)	Money from government, a local authority or a statutory authority, or money a government guarantees	Source as stated	Rare
(ii)	Money from foreign governments, foreign banks, multilateral institutions, foreign bodies corporate, foreign citizens and persons resident outside India	Subject to FEMA	Common
(iii)	Loans from banking companies, SBI, notified banking institutions or cooperative banks	Lender as stated	Common
(iv)	Loans from public financial institutions, regional financial institutions, insurance companies or scheduled banks	Lender as stated	Occasional
(v)	Commercial paper issued under RBI guidelines	RBI conditions	Rare
(vi)	Money from any other company	Lender is an Indian company	Common
(vii)	Share application money pending allotment	Allot in 60 days or refund in the next 15; use only for allotment	Common
(viii)	Money from a director, or a private company director's relative	Written declaration; disclosure in the Board's report	Common
(ix)	Secured bonds or debentures, or debentures compulsorily convertible within ten years	Security within valuer's market value	Occasional
(ixa)	Listed non convertible debentures without a charge	SEBI listing	Rare
(x)	Interest free security deposit from an employee	Up to annual salary	Occasional
(xi)	Interest free money held in trust	Held in trust	Rare
(xii)(a)	Advance for goods or services	Appropriated within 365 days, unless in court proceedings	Common
(xii)(b)	Advance for immovable property	Adjusted under the agreement	Rare
(xii)(c)	Security deposit for performance of a supply contract	Linked to the contract	Common
(xii)(d)	Advance under long term capital goods projects	Outside item (b)	Occasional
(xii)(e)	Advance for future warranty or maintenance services	Written agreement; up to common practice or five years, whichever is less	Occasional
(xii)(f)	Advance allowed by a sectoral regulator or government	As allowed	Rare
(xii)(g)	Advance subscription for publications	Adjusted against publications	Rare
(xiii)	Promoter loans that a lending bank requires	Only until the bank loan is repaid	Occasional
(xiv) to (xvi)	Nidhi deposits, chit subscriptions and collective investment scheme money	Their own laws	Not relevant
(xvii)	Convertible note of INR 25,00,000 or more, in one tranche, to a DPIIT recognised startup	Convert or repay within ten years	Rare
(xviii)	Money from SEBI registered AIFs, venture capital funds, InvITs, REITs and mutual funds	SEBI registration	Occasional

The proviso after item (g) adds one trap. An advance under item (a), (b) or (d) becomes a deposit if it turns refundable because the company lacks a permission it needs. The Explanation fixes the date at 15 days after the refund falls due.

Is a loan from a foreign parent a deposit?

No, as long as the loan complies with FEMA. Rule 2(1)(c)(ii) excludes money from foreign bodies corporate and persons resident outside India, subject to the Foreign Exchange Management Act, 1999 (FEMA). Under FEMA, a parent loan to an Indian company is an external commercial borrowing (ECB). You report its 31 March balance in DPT-3 under clause (ii).

RBI rewrote the ECB rules in 2026. The Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations, 2026 are Notification No. FEMA 3(R)(5)/2026-RB of 9 Feb 2026. They define an ECB as borrowing by an eligible borrower from a recognised lender under Schedule I. Any person resident outside India is a recognised lender, so a foreign parent qualifies.

Under the 2026 regulations, a parent loan must meet these conditions:

Condition	Rule for a parent loan in 2026
Minimum average maturity period	Three years (a manufacturing borrower may take one to three years, up to USD 150 million outstanding)
Borrowing limit	USD 1 billion of ECB, or total borrowing of 300% of net worth, whichever is higher
Cost	Market rate, at arm's length for a related party lender
Registration	Loan Registration Number (LRN) through the authorised dealer (AD) bank before drawdown
Reporting	Form ECB 2 through the AD bank, within seven calendar days after the end of each month with a drawdown or debt servicing
End use	No barred use, such as real estate business or trading in securities

The words "subject to FEMA" matter. The rule does not say what happens to a loan that breaks FEMA, and we read clause (ii) as protecting only a compliant loan. If the parent lent without an LRN, fix it through the AD bank or RBI compounding first. Report the balance under clause (ii) and tell the auditor about the gap. Our guide to an ECB loan from a foreign parent covers the RBI steps.

Two parent receipts get mixed up with loans. An advance for shares is share application money under clause (vii), with its own 60 day clock. Compulsorily convertible debentures (CCDs) are equity instruments under FEMA and fall under clause (ix).

How should a foreign owned company report its usual receipts?

Map every credit balance that came from money received to one head, then report the balance on 31 March. The table shows the heads we use for the receipts we see most. Anything marked as a deposit needs the deposit part of the form and the auditor's declaration.

Receipt on the books	Head under rule 2(1)(c)	Deposit?	What to report
Term loan from the foreign parent, with an LRN	(ii)	No	Principal at the 31 March closing rate
Parent's advance for shares, under 60 days	(vii)	No	Amount pending allotment
Share money not allotted in 60 days nor refunded in the next 15	Explanation to (vii)	Yes	Deposit part and list of depositors
CCDs held by the parent	(ix)	No	Face value outstanding
Loan from an Indian holding or fellow subsidiary company	(vi)	No	Principal outstanding
Bank working capital loan	(iii)	No	Balance outstanding
Director's loan with a written declaration	(viii)	No	Balance outstanding
Director's loan without a declaration	None	Yes	Deposit part; take advice on section 73
Indian customer advance, under 365 days	(xii)(a)	No	Unadjusted balance
Indian customer advance, over 365 days, no court case	None	Yes	Deposit part and list of depositors
Foreign customer advance	(ii) in our reading, or (xii)(a)	Not under (ii) if FEMA compliant; under (xii)(a), not within 365 days	Unadjusted balance
Customer security deposit under a supply contract	(xii)(c)	No	Balance held
Trade payable to the parent for invoiced services	Not money received	No	Leave out

We read clause (ii) as also covering an advance from a customer outside India, subject to FEMA. The rule does not settle this, and some advisers use clause (xii)(a) for every customer advance. Under clause (xii)(a), the 365 day limit applies. Agree the head with your auditor and keep it from year to year.

Keep a working that ties each figure to the trial balance. Our financial reporting guide shows where these balances sit in the accounts. Rule 16 asks for the information as on 31 March. For each head, the working should also show the receipts and repayments during the year. You can then answer each field as the V3 form labels it.

When does share application money become a deposit?

Share application money is not a deposit under rule 2(1)(c)(vii) while it waits for allotment and is used only for it. If the company cannot allot within 60 days of receipt and does not refund within the next 15 days, the money becomes a deposit. Using the money for any other purpose does not count as a refund.

Three clocks run together when a foreign parent sends money ahead of an allotment:

Clock	Source	What it requires
Deposit Rules	Explanation to rule 2(1)(c)(vii)	Allot within 60 days, or refund within 15 days after day 60; otherwise a deposit
Private placement	Section 42(6) of the Companies Act, 2013	Allot within 60 days, or refund within 15 days after day 60; later refunds carry 12% interest a year from day 60
FEMA	FEMA rules on non debt instruments, 2019	Issue shares within 60 days of receipt, or refund within 15 days after day 60

After allotment, the company reports to RBI in Form FC-GPR within 30 days. Our FC-GPR timeline guide sets out the steps. Money still unallotted after day 75 breaches all three clocks, so refund it or take advice at once.

In DPT-3, report money pending allotment on 31 March under clause (vii). If it crossed day 75 before 31 March, it goes in the deposit part. For a rights issue, see our note on a rights issue to a foreign parent.

When does a customer advance become a deposit?

Rule 2(1)(c)(xii)(a) exempts an advance for goods or services only if the company appropriates it against supply within 365 days. After day 365, the unadjusted balance is a deposit. The time limit does not apply while the advance is the subject of legal proceedings before a court.

Appropriate means adjust the advance against goods supplied or services provided, usually through invoices. A journal that moves the balance to another ledger appropriates nothing.

Technology subsidiaries should watch prepaid contracts that run for several years. Suppose an Indian customer pays three years of services upfront. On our reading, the share for years two and three cannot be appropriated within 365 days, so it risks becoming a deposit on day 366. The rule does not deal with multi year prepayments directly. Item (e) covers only a warranty or maintenance contract, and we read a plain software subscription as outside it. Agree the treatment with your auditor before the first 31 March.

We age every customer advance each quarter. Anything older than 270 days goes on the board's list for adjustment or refund.

Is a loan from a director a deposit?

A director's loan is exempt under rule 2(1)(c)(viii) if two conditions hold. At the time of lending, the director gives a written declaration that the money is not borrowed from others. The company then discloses the loan in the Board's report. A private company may also borrow from a director's relative on the same terms.

The exemption looks at the lender's status on the day the company received the money. A person who was a director then stays covered after resigning. A declaration signed months later does not meet the rule.

Rule 16A adds a note in the financial statements. Every company notes money received from directors, and a private company also notes money from their relatives.

A loan from a shareholder who is not a director follows its own head. An Indian company shareholder falls under clause (vi) and a foreign one under clause (ii). An individual member of a private company makes a member deposit under section 73(2).

A director living outside India is a person resident outside India, so the loan must also comply with FEMA, which usually means the ECB route. Our guide on appointing a foreign national director covers the director's own filings.

Does DPT-3 need an auditor certificate?

The V3 form asks for the auditor's declaration only when the return reports deposits. Rule 16, as amended on 29 Aug 2022, asks for information "duly audited by the auditor of the company". It adds that the auditor submits a declaration in Form DPT-3. The MCA V3 instruction kit enables that declaration only for the two "return of deposit" purposes. A return of exempt particulars alone goes without it.

The kit says the statutory auditor declares the "particulars of deposits" and the "particulars of liquid assets", with a membership number. Neither part exists in a return of exempt receipts alone.

Rule 16 still speaks of audited information for the whole return, though. So we take exempt figures from the audited balance sheet, or agree them with the auditor before we file.

Purpose selected in DPT-3	Auditor's declaration	Typical foreign owned case
Particulars of transactions not considered as deposit	Not required	Parent ECB, director loan with a declaration, customer advances under 365 days
Return of deposit	Required	A company with deposits and no exempt balances
Return of deposit and particulars	Required	Exempt balances plus a deposit, such as a customer advance past day 365

If the company holds any deposit on 31 March, plan the audit so the declaration is ready by 30 June. An exempt only return should still agree with the audited balance sheet. If the audit changes a figure after filing, record it and agree the next step with the auditor. Our note on the statutory audit of a foreign owned subsidiary sets out the audit calendar.

How do you file DPT-3 on the MCA V3 portal?

Log in to the MCA V3 portal, open the DPT-3 web form and choose the purpose. Enter the 31 March figures, add the auditor's declaration if you report deposits, and attach the depositor list where needed. An authorised director or officer signs with a digital signature certificate (DSC), and paying the fee generates the service request number (SRN).

The instruction kit sets out the fields. These points trip up foreign owned companies:

1. The CIN fills in for a company user, and a professional searches by name. Name, registered office and email come from MCA records.
2. Choose the particulars purpose only when no deposit exists on 31 March.
3. Answer No to the government company question. A private company cannot answer Yes to accepting public deposits.
4. The period must be 31 March.
5. Deposit fields open only for the deposit purposes. They cover depositor counts, matured deposits, deposits maturing next year, charges and credit rating.
6. Enter the board resolution number and date that authorise the signatory.
7. A director signs with a DIN, a manager, CEO or CFO with a DIN or PAN, and a company secretary with a membership number.
8. The kit says an exempt only return runs in straight through processing (STP), so the portal approves it without ROC review. Check every figure before you submit. A return that reports deposits runs in non STP mode, and the ROC may send it back for resubmission.

Attachment or record	When it is needed	Format and limit
List of depositors	Deposits outstanding are more than zero	Excel, in the MCA template
Copy of trust deed	Secured deposits, with a CHG-1 or CHG-9 SRN entered	PDF or JPG, 2 MB
Optional attachments	Any support, such as the exempt schedule	Up to five files, PDF or JPG, 2 MB each
All attachments together	Every filing	10 MB in total
Director declarations	Loans under clause (viii)	Keep on file for the auditor and ROC
LRN letter and Form ECB 2 copies	Parent loans under clause (ii)	Keep on file with the working
FC-GPR acknowledgement or refund proof	Share money under clause (vii)	Keep on file with the working

Our company compliance service runs this filing end to end and hands your auditor the mapping file.

What are the DPT-3 fees and late fees?

The normal DPT-3 fee is INR 200 to INR 600, based on nominal share capital. A late filing adds a fee of 2 to 12 times the normal fee, depending on the delay. The scale comes from the Companies (Registration Offices and Fees) Rules, 2014, and the MCA V3 kit repeats it.

Nominal share capital (INR)	Normal fee (INR)
Less than 1,00,000	200
1,00,000 to 4,99,999	300
5,00,000 to 24,99,999	400
25,00,000 to 99,99,999	500
1,00,00,000 or more	600
Company without share capital	200

The additional fee stops at 12 times the normal fee, so a company paying INR 600 risks at most INR 7,200 more. The penalties below matter more.

What is the penalty for not filing DPT-3?

Missing DPT-3 breaches rule 16. ROCs adjudicate it under section 454 of the Companies Act, 2013 and levy the general penalty in section 450. That is INR 10,000 on the company and each officer in default, plus INR 1,000 a day while the default continues. The cap is INR 2,00,000 for the company and INR 50,000 per officer.

The relief in section 454(3) for a default fixed within 30 days of a notice covers only sections 92(4) and 137. It does not cover DPT-3, so a late filing does not wipe out the penalty. An appeal against an order lies to the Regional Director within 60 days.

Rule 21 of the Deposit Rules adds a separate fine for breaching the rules. It is up to INR 5,000, plus up to INR 500 a day. Only a court can impose a fine. The ROC adjudication orders on DPT-3 defaults that we have seen apply section 450 instead.

Old defaults stay on the record. A company that missed the one time rule 16A return in 2019 is still in default of rule 16A(3). If the company existed then, check its MCA filing history.

Holding a deposit is heavier than a late return. Under section 76A, the company repays the deposit with interest and pays a fine. Each officer in default also faces prosecution, with the exposure set out in the table.

Consequence	Legal basis	Amount (INR)
Additional fee, delay up to 30 days	Fees Rules, Annexure	2 times the normal fee (1,200 on a 600 fee)
Additional fee, 31 to 60 days	Fees Rules, Annexure	4 times (2,400)
Additional fee, 61 to 90 days	Fees Rules, Annexure	6 times (3,600)
Additional fee, 91 to 180 days	Fees Rules, Annexure	10 times (6,000)
Additional fee, more than 180 days	Fees Rules, Annexure	12 times (7,200)
Penalty on the company	Section 450 with section 454	10,000 plus 1,000 a day, up to 2,00,000
Penalty on each officer in default	Section 450 with section 454	10,000 plus 1,000 a day, up to 50,000
Same default within three years	Section 454A	Twice the penalty
Fine under the Deposit Rules, on conviction by a court	Rule 21	Up to 5,000, plus up to 500 a day
Holding a deposit in breach of section 73, company	Section 76A(a)	Repay with interest; fine of 1,00,00,000 or twice the deposit, whichever is lower, up to 10,00,00,000
Same breach, each officer in default	Section 76A(b)	Exposure to prison of up to seven years and a fine of 25,00,000 to 2,00,00,000; section 447 if there was intent to deceive

If your DPT-3 is late, or a balance may have turned into a deposit, our compliance rescue team handles the catch up.

What changed in 2026

MCA relaxed the DPT-3 fee for one year and left DPT-3 out of its 2026 amnesty. RBI rewrote the ECB rules that clause (ii) depends on. India Code lists 29 Aug 2022 as the latest amendment to the Deposit Rules. We found no later one up to 27 Sep 2026. Check the MCA notifications page before you file, in case a change follows.

Area	Old position	New position	Date	Instrument
DPT-3 for FY 2025-26	Additional fee from 1 Jul 2026	No additional fee up to 31 Jul 2026; rule 16 date unchanged	19 Jun 2026	MCA General Circular No. 02/2026
MCA systems	Normal operation	Data centre fire, followed by restoration work that led to the DPT-3 relief	5 Jun 2026	Recited in General Circular No. 02/2026
Amnesty for old filings	No scheme open	CCFS-2026 for annual filing forms, 15 Apr to 15 Sep 2026; DPT-3 not covered	24 Feb 2026, extended 8 Jul 2026 and 31 Aug 2026	General Circulars No. 01/2026, 03/2026 and 04/2026
ECB rules for a parent loan	Master Direction on ECB; USD 750 million limit	ECB defined in FEMA regulations; USD 1 billion or 300% of net worth; three year minimum maturity; market cost at arm's length	9 Feb 2026	RBI Notification No. FEMA 3(R)(5)/2026-RB
Deposit Rules and Form DPT-3	Last amended 29 Aug 2022 (G.S.R. 663(E))	No change found up to 27 Sep 2026	Not applicable	Not applicable

Worked example

India Co is a private company, wholly owned by a US parent, with nominal share capital of INR 10,00,000. Its balances on 31 Mar 2026 are these:

1. An ECB of USD 600,000 from the parent for five years, with an LRN and Form ECB 2 filed. The books use a closing rate of INR 86.00 per USD. This rate is an assumption for the example, not the actual rate on 31 Mar 2026.
2. A loan of INR 40,00,000 from a resident Indian director, with a declaration signed on the day.
3. Share application money of INR 25,00,000 from the parent, received on 15 Jan 2026 and not yet allotted.
4. An advance of INR 60,00,000 from an Indian customer, received on 24 Feb 2025 and never adjusted, with no court case.

Item	Amount on 31 Mar 2026 (INR)	Head	Deposit?	Place in DPT-3
ECB from the parent (USD 600,000 × 86.00, assumed rate)	5,16,00,000	Rule 2(1)(c)(ii)	No	Exempt particulars
Director's loan with a declaration	40,00,000	Rule 2(1)(c)(viii)	No	Exempt particulars
Share application money, day 75	25,00,000	Rule 2(1)(c)(vii)	Not yet; a deposit from 1 Apr 2026 if not refunded	Exempt particulars
Customer advance, day 400	60,00,000	None; item (xii)(a) lapsed on day 366	Yes	Deposit part and list of depositors
Total exempt particulars	5,81,00,000
Total deposits	60,00,000

The ECB is exempt because it meets FEMA. The director's loan is exempt because the declaration existed on the day. The FY 2025-26 Board's report and the notes to the accounts must disclose it.

The share money shows why the clock matters. Day 60 fell on 16 Mar 2026, and the refund window closes on 31 Mar 2026, day 75. On 31 March the money is still inside the window, so it goes under clause (vii).

India Co has already missed the 60 day limit under FEMA. It should refund the parent by outward remittance, or take advice before any late allotment. If India Co has not refunded it by 1 Apr 2026, the money is a deposit from that day. The return as on 31 Mar 2027 must then show it, if it is still outstanding.

The customer advance crossed day 365 on 24 Feb 2026. From 25 Feb 2026, India Co held an INR 60,00,000 deposit from someone who is not a member. The purpose must be "return of deposit and particulars", with the auditor's declaration. The list of depositors shows the customer with INR 60,00,000 outstanding.

Section 76A sets the minimum fine at the lower of INR 1,00,00,000 and twice the deposit. Twice INR 60,00,000 is INR 1,20,00,000, so the floor is INR 1,00,00,000. The ceiling is INR 10,00,00,000. India Co should supply against the advance or refund it now, and take legal advice on the period it stood as a deposit. Had it adjusted the advance by 24 Feb 2026, the return would carry exempt particulars only.

India Co's capital puts it in the INR 400 fee band. Filed by 31 Jul 2026, the return paid INR 400 and no additional fee.

A second company shows the cost of filing late. B Co has nominal share capital of INR 1,00,00,000, so its normal fee is INR 600. It has not filed its return as on 31 Mar 2026. If the portal counts from 30 Jun 2026, the fee moves like this:

Filing date	Days after 30 Jun 2026	Multiple	Additional fee (INR)	Total fee (INR)
31 Jul 2026	31	Nil, under General Circular No. 02/2026	0	600
27 Sep 2026	89	6 times	3,600	4,200
1 Oct 2026	93	10 times	6,000	6,600
1 Jan 2027	185	12 times	7,200	7,800

If the portal counts from 31 Jul 2026 instead, a filing on 27 Sep 2026 is 58 days late. That puts it in the 4 times band, an additional INR 2,400. Any section 450 penalty sits on top, at the ROC's discretion.

Common mistakes

1. Treating DPT-3 as a return only for companies with deposits. Fix: file the particulars option whenever an exempt balance exists on 31 March.
2. Reading General Circular No. 02/2026 as a new due date. Fix: plan for 30 June every year, because the 2026 relief covered FY 2025-26 only.
3. Collecting the director's declaration after the money arrives. Fix: have the director sign on the day of the transfer.
4. Letting customer advances run past 365 days. Fix: age advances each quarter and adjust or refund well before day 365.
5. Holding the parent's share money beyond 60 days. Fix: allot within 60 days and file FC-GPR within 30 days, or refund within the next 15 days.
6. Drawing a parent loan before the LRN. Fix: get the LRN through the AD bank first, and regularise any gap before you file.
7. Reporting intercompany trade payables as loans. Fix: report only money the company received.
8. Adding an auditor's declaration to an exempt only return, or leaving it out when a deposit exists. Fix: let the purpose decide.
9. Using one exchange rate in DPT-3 and another in the books. Fix: use the 31 March closing rate from the balance sheet.
10. Relying on CCFS-2026 for a missed DPT-3. Fix: file with the additional fee, because the scheme did not list DPT-3.

Checklist

1. Pull the 31 March trial balance and list every credit balance that came from money received.
2. Map each balance to one rule 2(1)(c) head, or mark it as a deposit.
3. Age customer advances against the 365 day limit and share money against the 60 plus 15 day limit.
4. Collect the written declarations from each director or relative who lent money.
5. Check the FEMA papers for every foreign loan: the LRN, Form ECB and Form ECB 2 returns.
6. Convert foreign currency balances at the 31 March closing rate used in the books.
7. Choose the purpose: particulars only, or return of deposits and particulars.
8. Get the statutory auditor's declaration if the return reports any deposit.
9. Pass a board resolution that approves the figures and authorises the signatory.
10. Confirm the signatory's DSC is valid and registered on the MCA V3 portal.
11. File the DPT-3 web form by 30 June and pay the fee.
12. Save the SRN, the challan and the filed form with the working file.

Send your 31 March trial balance through our contact page, and we will map each balance to a DPT-3 head.

Frequently Asked Questions

Does a company with no borrowings still file DPT-3?+

If the company has no deposit and no exempt receipt outstanding on 31 March, rule 16 has nothing to report. The Deposit Rules do not mention a nil return, and we read rule 16 as not needing one. Check carefully first. Customer advances, customer security deposits, employee deposits and share application money all count as receipts. Most foreign owned subsidiaries hold at least one. We record the decision in a board note when nothing is reportable.

Do NBFCs and banking companies file DPT-3?+

No. Rule 1(3) of the Companies (Acceptance of Deposits) Rules, 2014 keeps banking companies, NBFCs registered with RBI and housing finance companies outside the rules. RBI's own directions govern their deposit taking. A company that is not registered with RBI cannot rely on this exclusion, even if part of its business looks like lending.

Does a branch or liaison office of a foreign company file DPT-3?+

No. The Deposit Rules apply to companies formed under Indian company law, as section 2(20) of the Companies Act, 2013 defines them. A branch, liaison or project office of a foreign company is not such a company. It has its own annual filings, including Forms FC-3 and FC-4 with the ROC and an annual activity certificate for its AD bank.

Is a payable to the parent for services reported in DPT-3?+

No. DPT-3 reports receipts of money. A trade payable arises when the parent invoices the Indian company for services or cost recharges, and no money reaches the company. It stays out of the return. The answer changes if the parent sends cash in advance or lends money. Those receipts go under clause (ii), (vii) or (xii)(a) of rule 2(1)(c).

Which exchange rate applies to a foreign currency loan in DPT-3?+

Use the closing rate the company applied in its balance sheet on 31 March. That rate follows AS 11 or Ind AS 21, whichever framework the company uses. The same rate lets the auditor tie DPT-3 to the financial statements filed in AOC-4. Do not use the rate on the day the loan arrived.

Should accrued interest on a parent loan go into DPT-3?+

We report the principal outstanding on 31 March under rule 2(1)(c)(ii). Accrued interest is a liability, but the company never received it as money. Keep the Form ECB 2 returns and the lender's statement on file, so the principal in DPT-3 agrees with both the lender's records and the audited balance sheet.

Can a private company accept deposits from its members?+

Yes, but only within limits. Section 73(2) of the Companies Act, 2013 allows member deposits on conditions. MCA's exemption notification of 5 Jun 2015 (G.S.R. 464(E)), as amended on 13 Jun 2017, eases some of them for private companies. These remain deposits. They go in the deposit part of DPT-3, with the list of depositors and the auditor's declaration.

Is a security deposit from a customer a deposit?+

Not if it secures performance of a contract for goods or services. Rule 2(1)(c)(xii)(c) excludes such security deposits and sets no time limit. The deposit must link to a real supply contract. A so called security deposit with no contract behind it, or one that pays interest like an investment, risks being treated as a deposit.

Did CCFS-2026 cover late DPT-3 filings?+

No. The Companies Compliance Facilitation Scheme, 2026, under General Circular No. 01/2026 of 24 Feb 2026, listed annual filing forms such as AOC-4, MGT-7, MGT-7A and ADT-1. DPT-3 was not on the list. A company with an old DPT-3 default pays the full additional fee and stays exposed to the section 450 penalty.

Who can sign DPT-3 when all directors live abroad?+

A director with a DIN and a valid DSC can sign from anywhere. Foreign directors can obtain a DSC from an Indian certifying authority. The DPT-3 form also accepts a manager, CEO or CFO with a DIN or PAN, or a company secretary with a membership number. The form asks for the board resolution number and date, so pass the resolution first.

Can we file DPT-3 before the statutory audit is finished?+

The V3 form lets you file an exempt only return without the auditor's declaration, which covers only deposits and liquid assets. Rule 16 still asks for information duly audited by the auditor, so we file once the auditor has agreed the figures. If the return reports any deposit, the auditor must declare the figures first. Either way, DPT-3 should agree with the balance sheet the auditor signs.

Is a compulsorily convertible debenture held by the parent a deposit?+

No. Rule 2(1)(c)(ix) excludes debentures compulsorily convertible into shares within ten years. Under FEMA, CCDs issued to a foreign investor are equity instruments, reported in Form FC-GPR. We report outstanding CCDs under clause (ix). Optionally convertible or non convertible debentures issued to the parent are ECB, and they sit under clause (ii).

What was the one time DPT-3 return under rule 16A?+

Rule 16A(3) required every company other than a government company to report exempt receipts outstanding from 1 Apr 2014 to 31 Mar 2019. The return was due within 90 days from 31 Mar 2019. It was a one time filing. A company that missed it is still in default, so check the MCA filing history if the company existed in 2019.

Does DPT-3 need certification by a practising CA or CS?+

No. The DPT-3 web form carries no practising professional certificate. It needs the DSC of an authorised director or officer. Where the return reports deposits, it also carries the statutory auditor's declaration with the auditor's membership number. A practising professional may prepare and upload the form, but the company's signatory signs it.

How does DPT-3 relate to the AOC-4 financial statements?+

The two should tell the same story. Rule 16A asks the financial statements to disclose money received from directors, and from their relatives in a private company. Borrowings, advances and security deposits in the balance sheet should reconcile to DPT-3. We tie each DPT-3 figure to a ledger. Our AOC-4 and MGT-7 guide covers the accounts filing.

Sources

• Ministry of Corporate Affairs, Instruction Kit for Form No. DPT-3 (Return of deposits), MCA V3, read 27 Sep 2026, https://www.mca.gov.in/content/dam/mca-aem-forms/instructionkits/Instruction%20Kit_DPT-3.pdf
• Ministry of Corporate Affairs, General Circular No. 02/2026, relaxation of additional fees for DPT-3 for the year ended 31 Mar 2026, 19 Jun 2026, https://www.mca.gov.in/bin/dms/getdocument?mds=4SQtX5BW0SiRdGUtbQZgRA%3D%3D&type=open
• Ministry of Corporate Affairs, General Circular No. 01/2026, Companies Compliance Facilitation Scheme, 2026, 24 Feb 2026, listed on the MCA circulars page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
• Ministry of Corporate Affairs, General Circular No. 03/2026, extension of CCFS-2026 to 31 Aug 2026, 8 Jul 2026, listed on the MCA circulars page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
• Ministry of Corporate Affairs, General Circular No. 04/2026, extension of CCFS-2026 to 15 Sep 2026, 31 Aug 2026, listed on the MCA circulars page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
• Ministry of Corporate Affairs, General Circular No. 01/2025, relaxation of additional fees for 13 forms during the move from MCA21 V2 to V3, 16 Jun 2025, listed on the MCA circulars page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
• Ministry of Corporate Affairs, Circulars index, read 27 Sep 2026, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
• Ministry of Corporate Affairs, Notifications index, read 27 Sep 2026, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/notifications.html
• India Code, Companies Act, 2013 and the rules made under it, including the Companies (Acceptance of Deposits) Rules, 2014, the Companies (Acceptance of Deposits) Amendment Rules, 2022 of 29 Aug 2022 (G.S.R. 663(E)), and the Companies (Registration Offices and Fees) Rules, 2014, read 27 Sep 2026, https://www.indiacode.nic.in/handle/123456789/2114
• Reserve Bank of India, Foreign Exchange Management (Borrowing and Lending) (First Amendment) Regulations, 2026, Notification No. FEMA 3(R)(5)/2026-RB, 9 Feb 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13306&Mode=0