DIR-3 KYC is no longer an annual filing — most directors' next date is 2028, not this September

Every September for the last several years, the same reminder has gone out from this office: file your DIR-3 KYC before 30 September. This year the reminder is different — for most directors, there is nothing to file this month at all. The rule itself changed, not just the date on the calendar.

The Ministry of Corporate Affairs notified the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025 on 31 December 2025 (notification G.S.R. 943(E)), effective 31 March 2026. It rewrites Rule 12A — the rule that has required every director to file DIR-3 KYC every single year since FY 2019-20. From FY 2026-27 onward, that annual ritual is gone.

What actually changed

Under the old rule, anyone holding an active DIN as on 31 March had to file DIR-3 KYC (the detailed e-form, if any personal detail had changed since the last filing) or the simpler DIR-3 KYC-WEB (an OTP-only confirmation, if nothing had changed) by 30 September of the following year. Miss it, and the DIN was marked "Deactivated due to non-filing of DIR-3 KYC" — no MCA form could be signed against that DIN until it was reactivated with a flat ₹5,000 late fee, regardless of how many months the delay ran.

Under the new rule, the two forms are merged into one — Form DIR-3 KYC-Web — and it is filed once every three consecutive financial years, not every year. The due date has also shifted, from 30 September to 30 June of the year after the third financial year in the cycle. Example: a director of a Surat plastics-trading Pvt Ltd whose KYC was up to date for FY 2025-26 files nothing for FY 2026-27 or FY 2027-28 — the next filing window is 1 April to 30 June 2028.

Which bucket is your DIN actually in?

The cycle is anchored to when your DIN was allotted and whether your KYC record is already current — not to a date you get to choose. Three situations cover almost every director this firm deals with.

Your DIN was allotted on or before 31 March 2025, and your KYC was filed and current for FY 2025-26. You are folded straight into the new cycle. Nothing is due for FY 2026-27 or FY 2027-28; your next filing window opens 1 April 2028 and closes 30 June 2028 — nearly two years from now.

Your DIN was allotted during FY 2025-26 (any date between 1 April 2025 and 31 March 2026) — say, a director added to a company incorporated last winter. The three-year clock starts from that allotment year, so the first triennial filing window is 1 April to 30 June 2029, one year later than the group above.

You hold an active DIN as on 31 March 2026 but have never filed a DIR-3 KYC at all. This is the one group that still had a hard deadline this year — 30 June 2026 — and it has already passed. It happens most often with a DIN taken years ago for a company that never quite started, or a family member added as a director on paper and then forgotten. If that describes anyone in your company, check that DIN's status on the MCA portal today: a deactivated DIN cannot sign a single MCA filing, including the annual return your own company may be due to file later this financial year.

Why the deadline used to feel busier than it needed to be

Six identical deadlines in a row understandably built a habit — file in September, every September, without asking whether it was actually the year for it. The chart below lines up the old rule against the new one on the same calendar: the old rule created a filing event every single year; the new rule creates one roughly once every three years, and moves it two months earlier in the year.

What still hasn't changed

One part of Rule 12A is untouched: if a director's personal mobile number, email address or residential address changes, Form DIR-3 KYC-Web must still be filed within 30 days of that change — regardless of where the director sits in the three-year cycle. Example: a Surat director who shifts house in November 2026 and updates the personal address on record must still file within 30 days, even though the routine triennial filing isn't due until 2028. Filing this update does not reset the three-year clock either — it stays anchored to the original DIN allotment year, not to the date of the last update.

One form, not two

Also worth knowing before the next MCA portal login: the separate DIR-3 KYC e-form and the DIR-3 KYC-WEB service have been merged into a single Form DIR-3 KYC-Web. There is no longer a choice between "the full form because something changed" and "the web version because nothing changed" — every filing, whether a routine triennial confirmation or an event-based update, now goes through the same consolidated form.

Sources

This article is general information, not professional advice. Rules change; verify current provisions or contact the office for advice on your situation.