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XBRL Filing in India and Which Companies Must File AOC-4 XBRL (2026)

Which Indian companies file financial statements in XBRL, how the INR 5 crore and INR 100 crore tests apply to foreign owned subsidiaries, the C&I and Ind AS taxonomies, validation, deadlines and the errors we fix most.

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Compliance

CA NandiniCo-founder

23 Feb 2026Published

Reviewed by Nihal Srivastava23 Feb 2026

28 minute read15 questions answered at the end

Krystal7 Consultants · India entry, tax and compliance

XBRL Filing in India and Which Companies Must File AOC-4 XBRL (2026)

Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.

Rule 3 of the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015 sets four classes. A company files AOC-4 XBRL if it is listed in India or an Indian subsidiary of a listed company. It also files if it has paid up capital of INR 5 crore or turnover of INR 100 crore, or prepares Ind AS accounts. Banks, insurers, NBFCs and housing finance companies are exempt. The form is due within 30 days of the AGM.

This page explains who files in XBRL, how foreign owned subsidiaries cross the line, which taxonomy applies, how a filing is validated, and the errors we fix most often.

AI Overview Summary

Under rule 3 of the XBRL Rules, 2015, a company with paid up capital of INR 5 crore or turnover of INR 100 crore files AOC-4 XBRL. Listed and Ind AS companies also file.
Banks, insurers, non banking financial companies and housing finance companies are exempt from the XBRL Rules. Power sector companies are no longer on the exempt list.
A company that has once filed in XBRL keeps filing in XBRL in later years under rule 3(2), even after it falls below the INR 5 crore or INR 100 crore limits.
AOC-4 XBRL is due within 30 days of the AGM under section 137(1). A late filing pays INR 100 a day in additional fees, with no cap.
Since 14 Jul 2025, AOC-4 XBRL goes only through MCA V3. Rule 3(1A) adds a PDF of the signed financial statements, board's report and auditor's report to the XBRL file.

Which companies must file financial statements in XBRL?

Four classes, under rule 3(1) of the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015 (the XBRL Rules). Two are listed companies with their Indian subsidiaries, and Ind AS companies. The other two are companies with paid up capital of INR 5 crore or turnover of INR 100 crore. Each files AOC-4 XBRL under section 137.

The rule uses "or above" for both money tests. So paid up capital of exactly INR 5 crore, or turnover of exactly INR 100 crore, brings a company in. Meeting any one of the four classes is enough.

Class under rule 3(1)	Test	Typical foreign owned case
(i) Listed companies and their Indian subsidiaries	Any security listed on a stock exchange in India	Rare; a listing abroad by the parent does not make the Indian company listed
(ii) Paid up capital	INR 5 crore or more	Common, because FDI usually arrives as equity
(iii) Turnover	INR 100 crore or more	Larger trading, manufacturing and service subsidiaries
(iv) Ind AS companies	Required to prepare accounts under the Companies (Indian Accounting Standards) Rules, 2015	Subsidiaries with net worth of INR 250 crore or more, or within an Indian Ind AS group
Exempt	Non banking financial companies, housing finance companies, banking and insurance companies	Banks and NBFCs file through their own forms

The first class needs care with foreign groups. Section 2(52) defines a listed company as one with securities listed on a recognised stock exchange, which means an Indian exchange. A private subsidiary of a parent listed in New York or London is not an Indian subsidiary of a listed company. It enters XBRL only through the capital, turnover or Ind AS tests.

Our guide to AOC-4 and MGT-7 for foreign owned companies covers the rest of the annual filing cycle.

How do the INR 5 crore and INR 100 crore tests work for a foreign owned subsidiary?

Paid up capital counts the face value credited as paid up, not share premium. Turnover counts revenue recognised from goods and services. Section 2(64) and section 2(91) of the Companies Act, 2013 define the two terms. A subsidiary funded with INR 6 crore of share capital files in XBRL even with modest revenue.

Section 2(64) defines paid up share capital as the amount credited as paid up on shares issued. It excludes other amounts received on those shares. A parent that subscribes for shares of INR 10 face value at INR 100 adds only INR 10 a share to paid up capital. The INR 90 premium sits in securities premium and does not count.

Section 2(91) defines turnover as the "gross amount of revenue recognised in the profit and loss account" from goods, services or both. On our reading, that is revenue from operations, so interest and other income fall outside it.

MCA's XBRL policy FAQ takes a wider view. It says "Gross turnover (i.e. inclusive of duties and taxes)" is considered for the INR 100 crore test. The FAQ carries no date and cites no section. The two readings differ by the GST and other duties a company collects. A company near INR 100 crore should test turnover both ways. If the figure inclusive of duties and taxes crosses INR 100 crore, we file in XBRL, because that is MCA's stated position. We record the reading in the audit file.

Test	What counts	What does not count	Rule
Paid up capital INR 5 crore	Face value of equity and preference shares credited as paid up	Securities premium, share application money pending allotment, compulsorily convertible debentures	Section 2(64); rule 3(1)(ii)
Turnover INR 100 crore	Revenue from sale of goods and services recognised in the profit and loss account; MCA's FAQ adds duties and taxes	Other income such as interest	Section 2(91); rule 3(1)(iii); MCA policy FAQ
Ind AS	The Indian company's own Ind AS status, set by its net worth and Indian group	The parent's IFRS or US GAAP reporting	Rule 3(1)(iv); Ind AS Rules, rule 4

Rule 3 does not name a testing date. We test both limits on the financial statements being filed, at the balance sheet date for capital and for the full year for turnover. Where a capital injection lands late in the year, we check again before the audit closes.

Rights issues and fresh allotments push many subsidiaries over INR 5 crore. Our note on a rights issue by an Indian subsidiary to its foreign parent covers the allotment. Our paid up capital service handles the filings that follow it.

Which companies are exempt from XBRL filing?

Non banking financial companies, housing finance companies, and companies in banking and insurance. The second proviso to rule 3(1) of the XBRL Rules exempts them. The current proviso dates from G.S.R. 1372(E) of 6 Nov 2017. Power sector companies, exempt under the earlier text, are no longer on the list. MCA's policy FAQ confirms this and says all power sector companies now file under the XBRL taxonomy.

The exemption history matters when a group reads old guidance. The 4 Apr 2016 amendment exempted banking, insurance, power sector, NBFC and housing finance companies. The 2017 substitution kept the financial sector exemptions and dropped the power sector one. A power generation or distribution subsidiary above the limits now files in XBRL.

NBFCs on Ind AS file through their own form, AOC-4 NBFC (Ind AS). Banks and insurers report under their sector laws and regulators as well. MCA's policy FAQ reads the NBFC exemption as covering NBFCs registered with the RBI, or exempt from RBI registration but registered with another regulator such as SEBI, IRDAI or the National Housing Bank.

No size exemption exists below the classes. A company outside all four classes simply files plain AOC-4. Our guide to the statutory audit of a foreign owned subsidiary covers the audited accounts that both forms carry.

Does a company stay in XBRL once it crosses the limits?

Yes. Rule 3(2) of the XBRL Rules says a company that has filed under rule 3(1) "shall continue to file" in XBRL in later years. That holds even if it no longer falls within any class. G.S.R. 213(E) of 8 Mar 2018 inserted the sub rule.

Rule 3(3) adds the same rule for companies that filed under the earlier Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2011. A subsidiary that filed in XBRL back then stays in XBRL now.

This catches groups that reorganise. Suppose a subsidiary reduces its capital from INR 8 crore to INR 2 crore after a loss. It still files AOC-4 XBRL. The same applies where turnover falls below INR 100 crore after a lost contract.

We note the first XBRL year in the company's compliance file. The compliance calendar for 2026-27 shows where the AOC-4 date sits in the year.

Which XBRL taxonomy applies, C&I or Ind AS?

The taxonomy follows the accounting framework. A company that prepares statements under the Companies (Accounting Standards) Rules, 2006 uses the Commercial and Industrial (C&I) taxonomy in Annexure II of the XBRL Rules. A company on Ind AS uses the Ind AS taxonomy in Annexure II A. The first proviso to rule 3(1) sets this split.

The C&I taxonomy mirrors Division I of Schedule III to the Companies Act, 2013. The Ind AS taxonomy mirrors Division II. Our batch note on the Schedule III format covers the two divisions.

MCA's Ind AS filing manual names the "IND AS 2017" taxonomy, with the schema file in-ci-ent-2017-03-31.xsd. It tells filers that "the taxonomy as applicable for the relevant financial year is to be used". It also says "no extensions to the core Taxonomy will be allowed".

The Rules name no taxonomy version. Download the taxonomy and the validation tool for the financial year you are filing from the MCA XBRL page, as the filing manual instructs. We quote no version for the C&I taxonomy here, because the version that applies depends on the year being filed.

Accounting framework	Schedule III division	Taxonomy	Source in the XBRL Rules
Accounting Standards (Companies (Accounting Standards) Rules, 2006)	Division I	C&I taxonomy	First proviso to rule 3(1); Annexure II
Ind AS (Companies (Indian Accounting Standards) Rules, 2015)	Division II	Ind AS taxonomy	First proviso to rule 3(1); Annexure II A
NBFC on Ind AS	Division III	Not under these rules; AOC-4 NBFC (Ind AS)	Second proviso to rule 3(1)
Banking and insurance	Sector formats	Not under these rules	Second proviso to rule 3(1)

A foreign owned subsidiary rarely chooses Ind AS voluntarily. Our batch note on Ind AS applicability for a foreign owned private company explains the INR 250 crore net worth test and the group rules.

What is the difference between AOC-4, AOC-4 XBRL and AOC-4 CFS?

All three file financial statements under section 137, but they cover different companies. AOC-4 carries form fields and PDF attachments for a company outside the XBRL Rules. AOC-4 XBRL carries a tagged instance document for a company inside them. AOC-4 CFS carries consolidated statements for a company outside the XBRL Rules.

Form	Who files it	What it carries	Rule
AOC-4	Every company outside the XBRL Rules	Standalone financial statements as form data and PDFs	Rule 12 of the Companies (Accounts) Rules, 2014
AOC-4 CFS	A company outside the XBRL Rules that prepares consolidated statements	Consolidated financial statements	Section 129(3); rule 12 of the Accounts Rules
AOC-4 XBRL	A company within rule 3 of the XBRL Rules	Instance documents for the standalone and, where required, consolidated statements, plus the signed PDF	Rule 3(1) and (1A) of the XBRL Rules
AOC-4 NBFC (Ind AS)	NBFCs on Ind AS	Ind AS financial statements of the NBFC	Accounts Rules

Consolidated statements arise under section 129(3) only where the company has a subsidiary, associate or joint venture of its own. Most foreign owned subsidiaries have none, so they file standalone statements only. MCA's Ind AS filing manual says "separate instance documents need to be prepared for consolidated financial statements".

Rule 6 of the Companies (Accounts) Rules, 2014 exempts some intermediate holding companies from consolidation. Check its conditions before assuming the foreign parent's group accounts cover an Indian sub group.

How is an AOC-4 XBRL filing prepared and validated?

The company or its service provider maps the audited financial statements to the taxonomy and builds an instance document. MCA's validation tool then checks the file against the taxonomy and the business rules. The filer converts it to PDF, compares the PDF with the signed accounts, and attaches the file to AOC-4 XBRL.

MCA's Ind AS filing manual sets the sequence. The manual predates MCA V3, where the web form replaces the old form checks. The C&I process follows the same pattern with its own taxonomy:

Create the instance document by mapping each figure and note to a taxonomy element.
Download MCA's XBRL validation tool and the taxonomy for the financial year.
Load the instance document in the tool and run the validation.
Correct every error, then run the tool's pre scrutiny, which needs an internet connection.
Leave the file untouched after a successful pre scrutiny. The manual warns: "Do not open and edit the instance document post successful Prescrutiny."
Export the instance to PDF and check it against the financial statements adopted at the AGM.
Fill AOC-4 XBRL, select the taxonomy, and attach the instance document.
Attach the signed financial statements as a PDF under rule 3(1A), sign with DSCs and submit.

MCA's validation tool page adds a limit on what validation proves. A file that passes the tool meets the taxonomy and business rules. It does not by itself show compliance with section 129, and the filed document must match the statements adopted at the AGM.

We prepare the XBRL file only after the board approves and the auditor signs. A file built from draft accounts almost always needs a rebuild. Our company compliance service runs the mapping, validation and filing as one task.

What must go with AOC-4 XBRL since 14 Jul 2025?

A PDF of the signed financial statements, with the board's report, the auditor's report and other documents. Rule 3(1A) of the XBRL Rules requires it. G.S.R. 371(E) of 6 Jun 2025 inserted the sub rule from 14 Jul 2025. The XBRL file alone no longer completes the filing.

The rule asks for statements "duly authenticated as specified in section 134". Under section 134(1), the board approves the statements and the specified directors sign them, along with the CFO and company secretary where the company has them. The auditor's report carries the auditor's signature and UDIN.

The same date moved the annual filing forms to MCA V3, as part of MCA's final set of 38 forms. G.S.R. 357(E) of 30 May 2025 (Companies (Accounts) Second Amendment Rules, 2025) added rule 12(1C) to the Accounts Rules. It requires separate forms with extracts of the board's report and of the standalone and consolidated auditor's reports to be filed along with AOC-4 and related forms.

A foreign director can sign on V3 with a Class 3 DSC linked to a V3 user ID and an active DIN. Many groups let the resident director sign, so the timetable does not depend on a director abroad. Our guide on financial reporting for foreign subsidiaries covers the group pack around these filings.

When is AOC-4 XBRL due, and what does a late filing cost?

Within 30 days of the AGM, under section 137(1) of the Companies Act, 2013. Where the AGM is not held, the 30 days run from the last date on which it should have been held. The deadline is the same as for plain AOC-4. XBRL preparation does not extend it.

A private company holds its AGM within six months of the year end, so by 30 Sep for a 31 March year. A company that held its AGM on 30 Sep 2026 must file AOC-4 XBRL for FY 2025-26 by 30 Oct 2026. A company that held its AGM earlier has an earlier date.

Item	Amount or effect	Rule
Normal fee	INR 200 to INR 600, by nominal share capital	Companies (Registration Offices and Fees) Rules, 2014
Additional fee for delay	INR 100 for each day of delay, no cap	Section 403(1); Fees Rules
Penalty on the company	INR 10,000 plus INR 100 a day, up to INR 2,00,000	Section 137(3)
Penalty on the MD and CFO, or the director in charge	INR 10,000 plus INR 100 a day after the first, up to INR 50,000	Section 137(3)
Three years without financial statements filed	Every director disqualified for five years	Section 164(2)(a)

The additional fee lets the ROC accept a late form. It does not settle the penalty. Section 403(2) keeps the section 137(3) penalty alive, and the ROC adjudicates it under section 454.

What are the common XBRL errors and how do you fix them?

Most errors come from three sources: format rules in the taxonomy, missing comparatives, and a mismatch between the XBRL file and the signed accounts. MCA's filing manual lists the format rules. The mismatch errors come from editing the accounts after tagging. The tool catches the first two, and only a careful review catches the third.

Error	Cause	Fix	Source
Identity or CIN error	Wrong identifier scheme or a CIN with a typo	Use the MCA CIN scheme and the company's own CIN in every context	MCA Ind AS filing manual
Date format error	Dates entered as 31/03/2026	Use the `yyyy-mm-dd` format	MCA Ind AS filing manual
Percentage reported as 60 instead of 0.6	Percentages entered as whole numbers	Enter fractions, such as 0.6 for 60 percent	MCA Ind AS filing manual
Unit error	Currency written as "Rs"	Use INR as the unit for monetary facts	MCA Ind AS filing manual
Decimals error	Figures in lakhs or crores tagged as rupees	Tag the full amount with decimals matching the accuracy; no scale factor	MCA Ind AS filing manual
Missing previous year value	Current year tagged without the comparative	Tag both years, except in the first financial year	MCA Ind AS filing manual
Roll forward mismatch	Opening plus movements do not equal closing	Reconcile the note before tagging	MCA Ind AS filing manual
Text block rejected	Inline styles, unclosed tags or a bare "&"	Use the allowed lowercase tags and escape "&"	MCA Ind AS filing manual
XBRL figures differ from the signed PDF	Accounts changed after tagging	Freeze the accounts first; rebuild and revalidate after any change	Our practice
Wrong form	Company filed plain AOC-4 though rule 3(2) applies	Check the company's first XBRL year before every filing	Rule 3(2) of the XBRL Rules

The scale error is the one we see most in foreign owned subsidiaries. Group packs report in thousands of US dollars, and Indian statements often present figures in lakhs. The taxonomy wants full rupee amounts with the decimals attribute set to match.

Comparatives cause the second most common rework. A company filing in XBRL for the first time still tags last year's figures, unless it is the company's first financial year. We build both years from the signed accounts, not from last year's plain AOC-4.

Who signs and certifies AOC-4 XBRL?

A director signs AOC-4 XBRL with a DSC registered on MCA V3. The board resolution names the signatory. We also have a Chartered Accountant or a Company Secretary in practice review and certify the form before filing. The auditor's signature sits on the auditor's report inside the attached PDF, not on the form.

The reviewing professional checks that the particulars match the company's records, so the XBRL review is more than a clerical step. We keep a tie out schedule from each tagged total to the signed statements in the file.

A director signing AOC-4 XBRL needs an active DIN and a valid DSC. DIR-3 KYC now runs once every three years under G.S.R. 943(E). A director already compliant is next due by 30 Jun 2028, so a lapsed KYC rarely blocks a filing now.

What changed in 2025 and 2026

The XBRL classes did not change in 2026. The filing route changed on 14 Jul 2025, when AOC-4 XBRL moved to MCA V3 with a signed PDF attached. The 2026 changes came from a one time fee scheme and a pending Bill.

Area	Old position	Position on 23 Oct 2026	Date	Instrument
Signed PDF with XBRL	XBRL instance only	PDF of signed statements, board's report and auditor's report also attached	14 Jul 2025	Rule 3(1A), inserted by G.S.R. 371(E) of 6 Jun 2025
Filing portal	AOC-4 XBRL on MCA V2	AOC-4 XBRL and the other annual filing forms on MCA V3	14 Jul 2025	MCA final set of 38 forms; extract forms under rule 12(1C), inserted by G.S.R. 357(E) of 30 May 2025
Late fee relief	Full additional fee	CCFS-2026 window for overdue annual filings, now closed	15 Apr to 15 Sep 2026	General Circulars 01/2026, 03/2026 and 04/2026
Small company limits	INR 4 crore capital, INR 40 crore turnover	INR 10 crore and INR 100 crore; no change to the XBRL limits	1 Dec 2025	G.S.R. 880(E)
Companies Act amendments	Current Act	Corporate Laws (Amendment) Bill, 2026 introduced and referred to a Joint Committee; not passed	23 Mar 2026	Bill No. 85 of 2026

The small company change does not move the XBRL limits. A small company with INR 6 crore of paid up capital still files AOC-4 XBRL under rule 3(1)(ii).

What has happened since 23 Feb 2026

MCA announced the Companies Compliance Facilitation Scheme, 2026 in General Circular No. 01/2026 on 24 Feb 2026, the day after this page first went up. The window ran from 15 Apr 2026 and, after two extensions, closed on 15 Sep 2026. The extensions came through General Circulars No. 03/2026 of 8 Jul 2026 and No. 04/2026 of 31 Aug 2026.

The scheme covered overdue financial statement filings, including AOC-4 XBRL. A company paid 10 percent of the additional fee and the normal fee in full. The window has closed, so the full INR 100 a day applies again.

The Lok Sabha introduced the Corporate Laws (Amendment) Bill, 2026 on 23 Mar 2026 and referred it to a Joint Committee. We found no record of Parliament passing it by 23 Oct 2026.

Worked example

Kiwi Analytics Limited, a New Zealand company, owns Kiwi Analytics India Private Limited. The Indian company had paid up capital of INR 4 crore and follows the Accounting Standards of 2006, not Ind AS. On 10 Jan 2026, it allots 20,00,000 equity shares of INR 10 each at INR 25 a share to its parent. The facts are hypothetical.

The capital test

Face value added: 20,00,000 × INR 10 = INR 2,00,00,000.
Securities premium: 20,00,000 × INR 15 = INR 3,00,00,000, which does not count.
Paid up capital at 31 Mar 2026: INR 4 crore + INR 2 crore = INR 6 crore.
INR 6 crore is above INR 5 crore, so FY 2025-26 accounts go in AOC-4 XBRL on the C&I taxonomy.

Revenue from operations is INR 30 crore and other income INR 1.2 crore. Turnover under section 2(91) is INR 30 crore, well below INR 100 crore. The capital test alone brings the company in.

The deadline and the cost of a delay

Step	Date or amount
AGM for FY 2025-26	10 Aug 2026
AOC-4 XBRL due (30 days)	9 Sep 2026
Actual filing	23 Sep 2026
Days late	14
Normal fee (authorised capital of INR 10 crore)	INR 600
Additional fee: INR 100 × 14	INR 1,400
Total paid to MCA	INR 2,000
Company penalty exposure: INR 10,000 + (INR 100 × 14)	INR 11,400
Exposure per officer: INR 10,000 + (INR 100 × 13)	INR 11,300

The penalty figures are exposure, not a bill. They arise only if the ROC adjudicates under section 454.

Later years

In FY 2027-28, the parent decides to cut costs and the company reduces its capital to INR 3 crore under a Tribunal order. Rule 3(2) still applies. The company files AOC-4 XBRL for FY 2027-28 and every later year.

Common mistakes

Counting share premium in paid up capital. Fix: test only the face value credited as paid up, under section 2(64).
Treating the parent's foreign listing as a listing. Fix: apply rule 3(1)(i) only to securities listed on an Indian exchange.
Testing turnover on total income. Fix: use revenue from goods and services under section 2(91), and retest inclusive of duties and taxes, as MCA's FAQ says.
Dropping back to plain AOC-4 after capital falls. Fix: apply rule 3(2) and keep filing in XBRL.
Relying on the old power sector exemption. Fix: read the proviso as substituted by G.S.R. 1372(E) of 6 Nov 2017.
Tagging draft accounts. Fix: build the instance only after the board approves and the auditor signs.
Editing the file after pre scrutiny. Fix: rebuild and revalidate if anything changes.
Forgetting the signed PDF. Fix: attach the authenticated statements and reports under rule 3(1A).
Leaving XBRL to the last week. Fix: start the mapping when the audit closes, not when the AGM ends.

Checklist

Test paid up capital, turnover, listing and Ind AS status on the year's audited figures.
Check whether the company filed in XBRL in any earlier year, which keeps it in under rule 3(2).
Confirm that the company is not an NBFC, housing finance, banking or insurance company.
Choose the C&I or Ind AS taxonomy to match the accounting framework.
Freeze the signed financial statements, board's report and auditor's report.
Map every figure and note to the taxonomy and build the instance document.
Validate the instance with MCA's tool and clear every error.
Export the instance to PDF and tie it out to the signed statements.
Prepare a separate instance for consolidated statements where section 129(3) applies.
Attach the instance and the signed PDF to AOC-4 XBRL on MCA V3.
Have a director sign with a DSC and a professional in practice review the form.
File within 30 days of the AGM and keep the SRN and challan in the compliance file.

If your subsidiary has crossed INR 5 crore of paid up capital, email [email protected] with the audited accounts and AGM date.

Key terms

Extensible Business Reporting Language (XBRL): A machine readable format in which each figure and disclosure in a financial statement carries a tag from a published taxonomy. Indian companies covered by the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015 file their financial statements with the Registrar in this format.
Form AOC-4 XBRL: The version of Form AOC-4 filed as a tagged XBRL file under the Companies (Filing of Documents and Forms in XBRL) Rules, 2015. It applies to listed companies and their Indian subsidiaries, companies with INR 5 crore paid up capital or INR 100 crore turnover, and Ind AS companies. Rule 3(1A) also requires a PDF of the signed statements.
Form AOC-4 CFS: The MCA form for filing consolidated financial statements prepared under section 129(3) of the Companies Act, 2013 by a company outside the XBRL Rules. A company within the XBRL Rules files its consolidated statements in XBRL instead, through a separate instance document.
XBRL taxonomy: The dictionary of tags and rules against which an XBRL file is prepared. The XBRL Rules, 2015 prescribe a Commercial and Industrial (C&I) taxonomy for companies on the Accounting Standards of 2006 and an Ind AS taxonomy for companies on Ind AS, as Annexures II and II A.
Instance document: The XBRL file that holds a company's tagged financial data for one set of financial statements. A company prepares one for its standalone statements and a separate one for its consolidated statements, validates each with MCA's tool, and attaches them to AOC-4 XBRL.
Indian Accounting Standards (Ind AS): The accounting standards converged with IFRS, notified under the Companies (Indian Accounting Standards) Rules, 2015. An unlisted company applies them from an Indian net worth of INR 250 crore, or when an Indian group company must. The size of a foreign parent is irrelevant. Other companies follow the Accounting Standards (AS).
Paid up share capital: Under section 2(64) of the Companies Act, 2013, the amount credited as paid up on shares issued, equal to the amount received as paid up. It excludes other amounts received on those shares, such as securities premium.

See the full glossary

Frequently Asked Questions

Which companies must file AOC-4 XBRL?

Rule 3(1) of the Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015 names four classes. Two are companies with paid up capital of INR 5 crore or turnover of INR 100 crore. The others are listed companies with their Indian subsidiaries, and Ind AS companies. NBFCs, housing finance, banking and insurance companies are exempt.

Is XBRL filing mandatory for a private limited company?

Only if it falls within a rule 3(1) class. A private company with paid up capital of INR 5 crore, turnover of INR 100 crore, or Ind AS accounts must file AOC-4 XBRL. A private company below all the limits, and not an Indian subsidiary of a listed company, files plain AOC-4.

Does share premium count towards the INR 5 crore paid up capital limit?

No. Section 2(64) of the Companies Act, 2013 defines paid up share capital as the amount credited as paid up on shares issued. It excludes other amounts received on those shares. A parent that pays INR 100 for a share of INR 10 adds only INR 10 to paid up capital.

What counts as turnover for the INR 100 crore XBRL test?

Section 2(91) of the Companies Act, 2013 defines turnover as the gross revenue recognised in the profit and loss account from goods, services or both. On our reading, that is revenue from operations, so interest and other income fall outside it. MCA's XBRL FAQ adds that gross turnover inclusive of duties and taxes is considered, so test both ways near the limit.

Is a subsidiary of a foreign listed company required to file in XBRL?

Not for that reason alone. Rule 3(1)(i) covers listed companies and their Indian subsidiaries, and section 2(52) ties a listing to a recognised stock exchange in India. A subsidiary of a parent listed only abroad files in XBRL only if it meets the capital, turnover or Ind AS test.

Can a company stop filing in XBRL when it falls below the limits?

No. Rule 3(2) of the XBRL Rules, inserted by G.S.R. 213(E) of 8 Mar 2018, requires a company that has filed in XBRL to continue in later years. That applies even if it no longer falls within any class. Rule 3(3) applies the same rule to companies that filed under the 2011 XBRL Rules.

Are power sector companies exempt from XBRL filing?

No longer. The proviso substituted on 4 Apr 2016 exempted the power sector. G.S.R. 1372(E) of 6 Nov 2017 substituted the proviso again and left power out. The current exemption covers NBFCs, housing finance companies, and companies in banking and insurance.

Which taxonomy should a company use for XBRL filing?

The taxonomy follows the accounting framework, under the first proviso to rule 3(1) of the XBRL Rules. A company on the Accounting Standards of 2006 uses the C&I taxonomy in Annexure II. A company on Ind AS uses the Ind AS taxonomy in Annexure II A. MCA's filing manual allows no extensions to the core taxonomy.

What is the due date for filing AOC-4 XBRL?

Within 30 days of the AGM, under section 137(1) of the Companies Act, 2013. If the company does not hold its AGM, the 30 days run from the last date for holding it. For a 30 Sep 2026 AGM, AOC-4 XBRL for FY 2025-26 is due by 30 Oct 2026.

What is the penalty for late filing of AOC-4 XBRL?

MCA charges an additional fee of INR 100 for each day of delay, with no cap. The ROC can also impose a penalty under section 137(3): INR 10,000 plus INR 100 a day on the company, up to INR 2,00,000. Officers face up to INR 50,000 each.

What is the difference between AOC-4 CFS and AOC-4 XBRL?

AOC-4 CFS files consolidated financial statements for a company outside the XBRL Rules. A company inside the XBRL Rules files its consolidated statements in XBRL instead, as a separate instance document attached to AOC-4 XBRL. Both arise only where section 129(3) requires consolidated statements.

Does AOC-4 XBRL still need a PDF of the financial statements?

Yes. Rule 3(1A) of the XBRL Rules, inserted by G.S.R. 371(E) of 6 Jun 2025 from 14 Jul 2025, requires a PDF of the signed financial statements. The board's report, auditor's report and other documents go with it. The XBRL instance and the PDF must match.

Does passing MCA's XBRL validation tool mean the filing is correct?

No. MCA's validation tool page says a file that passes meets the taxonomy and business rules. That does not by itself show compliance with section 129. The figures must still match the financial statements adopted at the AGM, so a manual tie out remains necessary.

Who certifies AOC-4 XBRL?

A director signs the form with a DSC registered on MCA V3. We have a Chartered Accountant or a Company Secretary in practice review and certify it before filing. The statutory auditor signs the audit report inside the attached PDF, not the form itself.

Can a foreign director sign AOC-4 XBRL?

Yes, if the director holds an active DIN and a Class 3 DSC linked to an MCA V3 user ID. Many groups let the resident director sign instead, so the filing date does not depend on a director abroad. The board resolution should name who signs.

Sources

Ministry of Corporate Affairs, Companies (Filing of Documents and Forms in Extensible Business Reporting Language) Rules, 2015, rule 3, as amended on 4 Apr 2016, by G.S.R. 1372(E) of 6 Nov 2017, G.S.R. 213(E) of 8 Mar 2018 and G.S.R. 371(E) of 6 Jun 2025, notifications page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/notifications.html
Ministry of Corporate Affairs, G.S.R. 357(E) of 30 May 2025 (Companies (Accounts) Second Amendment Rules, 2025, rule 12(1C), in force 14 Jul 2025) and G.S.R. 880(E) of 1 Dec 2025, notifications page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/notifications.html
Ministry of Corporate Affairs, XBRL page (rules, taxonomy and validation tool downloads), https://www.mca.gov.in/XBRL/
Press Information Bureau, MCA replaces annual director KYC with a KYC intimation once in three years (G.S.R. 943(E) of 31 Dec 2025), 1 Jan 2026, https://www.pib.gov.in/PressReleasePage.aspx?PRID=2210552&reg=3&lang=1
Ministry of Corporate Affairs, XBRL Filing Manual (Ind AS), accessed 23 Oct 2026, https://www.mca.gov.in/XBRL/pdf/Filing_Manual_IndAS_V1.0.pdf
Ministry of Corporate Affairs, XBRL Validation Tool page, accessed 23 Oct 2026, https://www.mca.gov.in/XBRL/valfy15.html
Ministry of Corporate Affairs, XBRL Policy Specific FAQs, accessed 23 Oct 2026, https://www.mca.gov.in/XBRL/Policy_specific_FAQs.html
Ministry of Corporate Affairs, General Circulars No. 01/2026 (24 Feb 2026), 03/2026 (8 Jul 2026) and 04/2026 (31 Aug 2026), circulars page, https://www.mca.gov.in/content/mca/global/en/acts-rules/ebooks/circulars.html
Ministry of Corporate Affairs, fee schedule under the Companies (Registration Offices and Fees) Rules, 2014, https://www.mca.gov.in/content/mca/global/en/mca/fo-llp-services/enquire-fees.html
Income Tax Department (Companies Act, 2013 text), Section 2, definitions including clauses 52, 64 and 91, accessed 23 Oct 2026, https://www.incometaxindia.gov.in/w/section-2-148
Income Tax Department (Companies Act, 2013 text), Section 137, copy of financial statement to be filed with Registrar, https://www.incometaxindia.gov.in/w/section-137-79
Income Tax Department (Companies Act, 2013 text), Section 403, fee for filing, https://www.incometaxindia.gov.in/w/section-403-2

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CA Nandini

Co-founder · All India Rank 49, ICAI

Nandini Hasija is a co-founder of Krystal7. She leads brand, business development and marketing, and works with founders to define their engagement. She is a Chartered Accountant and achieved All India Rank 49 in the CA examinations.

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