A Pune SaaS company has never taken a rupee of public deposit. To bridge a tight payroll month the founder-director put in ₹18 lakh of her own money. The books call it an unsecured director's loan and move on. That single entry is exactly what DPT-3 exists to capture — and the company secretary who waves it off as "we have no deposits" has just started a penalty clock.
DPT-3 is due every year by 30 June, reporting the position as on the preceding 31 March, and almost every company files it — because it captures director loans, inter-corporate loans and bank facilities, none of which are deposits.
The bottom line
Who: every company except government, banking, RBI-registered NBFC and NHB-registered housing finance companies — including a private limited with nothing but a director's loan outstanding.
By when: 30 June every year, reporting the position as on the 31 March immediately before. The next filing is due 30 June 2027 for the year ended 31 March 2027.
Miss it: an additional fee of 2 to 12 times the normal fee, plus up to ₹5,000 and ₹500 a day on the company and every officer in default.
What DPT-3 actually is
An annual return under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, in which a company tells the Registrar how much money it holds that came in as a loan, an advance or a deposit and is still outstanding on 31 March.
The name misleads. It reads as a return of deposits, so founders assume it only matters if they ran a deposit scheme. The 2019 amendment widened it considerably. The form now does two jobs: report any actual deposits, and report the long list of borrowings the law specifically says are not deposits but still wants on record.
That second bucket is where almost every private company lives, usually with nothing at all in the first.
The deadline
It does not move with the calendar. Report the position as it stood on 31 March, and file by 30 June of that same year. Three months, every year, with no reminder from the Registrar.
So the return for the year ended 31 March 2027 is due by 30 June 2027. The year after closes 31 March 2028 and falls due 30 June 2028, and so on.
There is no grace period in the rule. The additional fee starts the day after, and it is charged as a multiple of the normal fee rather than a flat late charge — which is why a filing that costs a few hundred rupees on time costs several thousand a few months later.
On extensions: the MCA occasionally relaxes the date for one year, and only for a specific reason. For the year ended 31 March 2026 it allowed filing up to 31 July 2026 without additional fees, through General Circular No. 02/2026 dated 19 June 2026, after a fire at the MCA Data Centre on 5 June 2026 forced restoration work on the MCA21 V3 portal. That was tied to that incident, set no precedent, and did not change the rule. Unless a circular says otherwise for the year you are filing, the date is 30 June.
Whether you file when you never took deposits
Almost certainly yes, and this is worth being blunt about: no public deposits does not mean no DPT-3. The form captures money the Act calls "not a deposit", and that category is enormous.
If any of these were outstanding on the 31 March you are reporting, you file:
- a loan from a director or a relative of a director;
- a loan from a holding, subsidiary or associate company;
- any inter-corporate loan from another company;
- a bank or NBFC term loan, working capital facility or overdraft;
- a convertible note above ₹25 lakh, subject to conditions;
- customer advances that have been sitting for more than 365 days.
The test that works is not a definition but a sequence. Are you a company under the Companies Act, 2013? Are you inside one of the four exempt categories, in which case you are out? Is anything at all outstanding on 31 March? If yes, you file — even where it is only a director's loan. If nothing is outstanding, a NIL return is best practice rather than a requirement.
Outstanding is not the same as exempt from reporting. That is the whole rule in one line.
Who is genuinely exempt
The list under Rule 16A(3) and the proviso to Section 73(1) is short and specific. If you are not on it, you file.
| Exempt entity | Why it's out |
|---|---|
| Government companies | Carved out at the root of the rule. |
| Banking companies | Regulated by the RBI under separate law. |
| NBFCs registered with the RBI | Already report to the RBI. |
| Housing-finance companies (registered with NHB) | Supervised by the National Housing Bank. |
Insurance companies are the grey area. There is no explicit line for them in the rule, but because they are regulated by IRDAI rather than the RBI, professional practice and MCA helpdesk responses generally treat them as outside DPT-3. If you advise an insurer, document the basis rather than assuming it.
What you report
Three buckets, sorted by the classification test in Rule 2(1)(c). Get an amount into the right one and the rest of the form is data entry.
| The money is… | Example | In DPT-3? |
|---|---|---|
| A genuine deposit | Public deposit; member deposit by a public company | Report — deposit |
| Not a deposit, but outstanding | Director loan, inter-company loan, bank/NBFC loan, convertible note | Report — exempted |
| Creates no liability / inside the time window | Share application money allotted within 60 days; customer advance settled within 365 days | Not reported |
The middle row is where people go wrong. Those amounts are exempt from the deposit rules, not from reporting. When you file them you cite the specific sub-clause of Rule 2(1)(c) that exempts each — for a director's loan in a private company that is Rule 2(1)(c)(viii), and it must be backed by the director's written declaration that the money is her own rather than borrowed funds passed through.
Whether you need an auditor's certificate
It depends on the return type you select, and this is the most misunderstood part of the form.
| You're filing… | Auditor's certificate? |
|---|---|
| Return of deposits | Required |
| Deposits and exempted receipts | Required |
| Only exempted receipts (the common case) | Not required |
So the typical private company reporting a director's loan and a bank facility needs no auditor's certificate. Where one is needed there is no prescribed format, and the ICAI has published an illustrative one that auditors generally adapt.
The form itself can be signed by a director, manager, CEO, CFO or company secretary. It does not require separate certification by a practising professional.
What missing it costs
Three separate cost layers, and conflating them is how the wrong number ends up in circulation.
The late fee. File after the deadline and the MCA stacks an additional fee on the normal filing fee, scaled to the delay.
| Delay | Additional fee |
|---|---|
| Up to 30 days | 2× normal fee |
| 30 – 60 days | 4× normal fee |
| 60 – 90 days | 6× normal fee |
| 90 – 180 days | 10× normal fee |
| Over 180 days | 12× normal fee |
The normal fee is small and based on share capital — from ₹200 where capital is under ₹1 lakh or there is no share capital, up to ₹600 at ₹1 crore or more.
The Rule 21 penalty. This is the one that bites for plain non-filing. The company and every officer in default can be fined up to ₹5,000, and where the default continues, a further ₹500 for every day it runs. It attaches to the people who signed, not only to the entity.
Section 73. The figures quoted elsewhere — up to ₹10 crore and imprisonment up to 7 years — are real, and they apply to actually accepting deposits in breach of the law, not to a late DPT-3 on exempt loans. Do not let anyone frame a missed return as a ₹10 crore event. Do take it seriously if the company has genuinely been taking deposits it should not.
A worked example
Back to the Pune company. As on 31 March 2027 its books show:
| Item | Amount |
|---|---|
| Director's loan (founder) | ₹18,00,000 |
| Bank working-capital facility | ₹40,00,000 |
| Customer advance, received Feb 2026 | ₹6,00,000 |
| Reportable as exempted receipts | ₹58,00,000 |
The director's loan goes in citing Rule 2(1)(c)(viii) and the bank facility under Rule 2(1)(c)(iii). The ₹6 lakh customer advance is under 365 days old, so it stays out for now. Total deposits are nil.
This is therefore not a NIL return — there is ₹58 lakh to report — and it needs no auditor's certificate, because it is a return of exempted receipts only.
Suppose instead they had believed "no deposits, no filing" and surfaced it 70 days late. The normal fee on ₹10 lakh of capital is ₹400, and the 60 to 90-day slab makes the additional fee six times that, so ₹2,400 on top — plus exposure to the Rule 21 fine on the company and on the officers who let it slip. A few thousand rupees and a director's name on a default list, to avoid an afternoon's work.
Common mistakes
- Concluding that no deposits means the form does not apply. This is the reason most late filings happen.
- Forgetting the director's declaration. A private company's director loan needs a written declaration that the funds are the director's own, and a note in the Board's report.
- Filing the wrong return type. Picking "Return of Deposits" when you have only exempted receipts triggers an auditor's certificate requirement you did not need, and often a query.
- Skipping the NIL return. Not strictly mandatory when nothing is outstanding, and filing it keeps the compliance trail clean.
- Assuming a mistake can be corrected easily. DPT-3 cannot simply be re-filed.
Before you file
- Pull the trial balance as on 31 March and list every loan, deposit and advance outstanding.
- Classify each amount as a deposit, exempted but reportable, or out of scope, noting the Rule 2(1)(c) sub-clause for the exempted ones.
- Collect the director's declaration for any director or relative loan in a private company.
- Confirm the net worth figure from the latest audited balance sheet.
- Pick the correct return type. For most companies that is exempted receipts only, with no auditor's certificate.
- File on the MCA21 V3 portal, pay the fee, and save the SRN and the challan.
Frequently asked questions
Is a NIL return mandatory? Not strictly, when nothing is outstanding on 31 March. Filing one is strong practice, because it documents that you considered the obligation.
Does a One Person Company have to file? Yes. OPCs, private limited, public limited and Section 8 companies are all within scope. Only the four exempt categories are out.
Are bank loans really reportable, when they are obviously not deposits? Yes. Loans from banks, NBFCs and financial institutions are exempted deposits under Rule 2(1)(c)(iii) — exempt from the deposit rules, still reported here.
What period does the return cover? The amounts outstanding as on 31 March, filed by 30 June that same year.
Can I revise a DPT-3 after filing? Not directly. You generally have to ask the Registrar to treat the original filing as defective before a corrected return is accepted.
Does a loan from my own company to another group company count? Yes. It is an inter-corporate loan in the hands of the company that received it, and reportable there as an exempted receipt.
Primary sources
- MCA General Circular No. 02/2026 dated 19 June 2026, on the DPT-3 fee relaxation
- Rules 16 and 16A, Companies (Acceptance of Deposits) Rules, 2014
- Rule 2(1)(c), on amounts not considered deposits
- Section 73, Companies Act, 2013, and Rule 21, on penalties