The AGM Isn't Over When It Ends: A During- and Post-Meeting Compliance Playbook for Listed, Unlisted Public and Private Companies

REGULATORY GUIDE · COMPANY LAW & SECRETARIAL COMPLIANCE

Content current as of 20 September 2026

Last updated: 28 September 2026

Authors: CS Ankur Jain: GC & CS – India Glycols Limited; FCS Monika Thareja Grover: Partner – CorpApex Partners

Quick Answer: every company except a One Person Company must hold an AGM (Companies Act, Section 96). All companies follow the same Companies Act and Secretarial Standard-2 (SS-2) framework apart from the relevant Articles of Association (AoA) for quorum, minutes, resolutions and post-AGM filings - but a listed company carries another layer, SEBI LODR Regulations, that adds e-voting for every resolution, a Report on AGM (MGT-15), a 2-working-day voting-results disclosure, and material-event reporting, none of which apply to unlisted public or private companies.

What Are the Key Takeaways on AGM Compliance in India?

AGM is mandatory for every company except an OPC (Section 96) - private, unlisted public and listed companies are all covered, but the compliance load differs sharply by category.
Four-layer framework: Companies Act 2013 (baseline, all companies) + AoA+ Secretarial Standard-2/SS-2 (mandatory procedural standard, all companies except OPC/Section 8) + SEBI LODR Regulations 2015 (additional layer, listed companies only - this replaced the erstwhile Listing Agreement in 2015).
During the AGM, the biggest differentiator is e-voting: mandatory for every listed company and for any company with 1,000+ members - which can never include a private company, since private-company membership is capped at 200.
Post-AGM, listed companies carry three extra obligations unlisted/private companies do not: filing MGT-15 (Report on AGM), submitting voting results to the stock exchange within 2 working days, and disclosing the AGM outcome as a material event.
Private companies get one real Companies Act concession: exemption from filing MGT-14 for routine Section 179(3) Board resolutions - special resolutions must still be filed.
Minutes deadlines (30-day signing/entry) and Annual Return/financial-statement filing deadlines (60/30 days from the AGM) apply identically across all three categories - and are the most commonly missed, regardless of company type.
MCA and SEBI/exchanges have both issued real, dated penalty orders for AGM-linked defaults in 2024–2026 - see the common-mistakes section below.

Which Laws Govern AGM Compliance: Companies Act 2013, Secretarial Standard-2 and SEBI LODR?

Companies Act, 2013 (Sections 96 to 122, read with the Companies (Management and Administration) Rules, 2014) - the baseline law: when an AGM must be held, notice, quorum, proxies, voting, minutes, and the filings that follow it. Applies to every company (private, unlisted public, listed) except One Person Companies, which are not required to hold an AGM at all (Section 122).
Secretarial Standard-2 (SS-2) on General Meetings, issued by the ICSI - made mandatory for all companies (other than OPCs and Section 8 companies, which may follow it voluntarily) by Section 118(10) of the Companies Act. SS-2 supplies the procedural detail: how minutes must read, how long records must be preserved, how a poll is conducted.
SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 ("SEBI LODR") - applies only to listed companies, as an additional layer on top of the Companies Act and SS-2. It replaced the erstwhile Equity Listing Agreement that stock exchanges used to execute with issuers; obligations that used to sit in specific clauses of that Agreement (e.g., the old Clause 35B on e-voting, Clause 47 on newspaper advertisements) now sit in the corresponding LODR regulations (Regulation 44, Regulation 47, and so on). There is no separate, currently-operative "Listing Agreement" running alongside LODR - LODR is its successor and is the current Law.
Practical reading: an unlisted public company and a private company are both governed by the same three layers (Companies Act + SS-2+AoA) - the practical difference between them shows up mainly in quorum and the Section 179(3)/MGT-14 exemption. A listed company carries another , materially heavier layer (SEBI LODR) on top of both.

Who Must Hold an AGM in India, and By When?

AGM is mandatory for every company (Section 96) - private limited, unlisted public and listed alike - except a One Person Company, which Section 122 exempts from holding any general meeting.
First AGM: within 9 months from the close of the first financial year.
Every subsequent AGM: within 6 months from the close of the financial year, and in any case not more than 15 months after the previous AGM.
The Registrar (through the Regional Director, by delegation) may extend the deadline for any AGM other than the first AGM, by up to 3 months, for special reasons.
Timing and day: must be held during business hours (9 a.m.–6 p.m.), on a day that is not a National Holiday.
Venue: registered office, or elsewhere within the same city/town/village as the registered office - except that an unlisted company may hold its AGM anywhere in India if all members consent in writing or electronic mode in advance (Section 96, second proviso). This flexibility is not available to a listed company.
Overlay for listed companies: SEBI additionally requires the top 100 listed entities by market capitalisation to complete their AGM within 5 months of the financial year-end (tighter than the Companies Act's 6-month rule) and to provide a live webcast of the proceedings.
If a company defaults, any member may apply to the NCLT (Sections 97/98), which can call the AGM itself and even direct that one member present in person or by proxy constitutes a valid quorum.

What Happens During the AGM: Activities and Requirements by Company Type?

Once the meeting opens, the requirements below apply. Listed, unlisted public and private companies follow the same Companies Act read with their AoA mechanics for quorum, proxies and minutes - the sharpest divergence is e-voting, which SEBI LODR makes mandatory for every listed company regardless of size.

Activity	Listed Company	Unlisted Public Company	Private Company
Quorum	5 members personally present if total members ≤1,000; 15 if 1,001–5,000; 30 if more than 5,000 (Section 103).	Same tiered thresholds as a listed company (Section 103) - quorum depends on total membership, not listing status.	2 members personally present (Section 103), regardless of total membership, unless the articles require more.
Attendance register for scrutinizer	Provide the attendance register or VC attendance report to the scrutinizer as an operational check supporting quorum and voting records. This does not transfer the Chairman's responsibility for ensuring quorum.	Same operational step where a scrutinizer is appointed for e-voting or a poll; otherwise retain the attendance record for the company's quorum check.	Same operational step where a scrutinizer is appointed for e-voting or a poll; otherwise retain the attendance record for the company's quorum check.
Mode of meeting (physical / VC-OAVM)	May be held via video conferencing/OAVM under MCA's standing circular (General Circular 03/2025, 22 Sep 2025, "till further orders"). Top-100 listed entities by market cap must additionally provide a one-way live webcast (LODR Reg. 44(6)).	Same VC/OAVM facility available under the same MCA circular. No separate webcast requirement - SEBI LODR does not apply.	Same VC/OAVM facility available. No webcast requirement.
Remote e-voting	Mandatory for every resolution at every general meeting, regardless of member count (SEBI LODR Reg. 44(1), read with Rule 20 of the Companies (Management and Administration) Rules).	Mandatory only if the company has 1,000 or more members (Rule 20); optional otherwise.	Not triggered in practice - private-company membership is capped at 200 (Section 2(68)), so the 1,000-member threshold can never be crossed.
Voting at the meeting (non-electronic)	Show of hands is effectively superseded - the combined remote e-voting and insta e-voting results determine the outcome.	Show of hands by default (one vote per member) unless a poll is validly demanded (Section 109) or e-voting applies.	Same default as an unlisted public company - show of hands, with a poll on valid demand.
Proxies	Proxy has no right to speak and may vote only on a poll/e-voting, not on a show of hands (Section 105). Instrument must reach the company ≥48 hours before the meeting. One person can act as proxy for up to 50 members holding, in aggregate, not more than 10% of voting share capital (Rule 19).	Same statutory proxy rules as a listed company (Section 105, Rule 19).	Same statutory proxy rules apply.
Scrutinizer	Mandatory wherever e-voting applies (i.e., always, for a listed company) - a Chartered Accountant, Company Secretary in practice, or Advocate not in the company's employment; consolidated report due not later than 3 days after the meeting (Rule 20(4)(ix)).	Mandatory only where e-voting applies (≥1,000 members) or a poll is demanded.	Mandatory only where a poll is demanded (e-voting essentially never applies).
Minutes-taking during the meeting	Chairman ensures minutes will fairly and correctly summarise proceedings - business transacted, resolutions, voting results, and members present in person/by proxy - with discretion to exclude defamatory or irrelevant matter (Section 118, SS-2).	Same requirement (Section 118, SS-2).	Same requirement (Section 118, SS-2).

What Are the Post-AGM Annual Compliance Requirements for Private Limited, Unlisted Public and Listed Companies?

Every deadline below runs from the date the AGM was actually held - not the date it was originally scheduled for. Where a meeting is adjourned, recalculate every downstream deadline from the adjourned date.

What Are the Practical Tips for Holding a Smooth AGM?

Fix the AGM date early against the 6-month/15-month clock, and build in buffer for the 21-day(Clear) notice period (or the shorter-notice consent route) - do not let notice timelines force a late meeting.
Reconcile the members' register and email addresses well in advance - VC/OAVM and e-voting both depend on the company holding current, valid email IDs.
Appoint the scrutinizer before the notice goes out, not after, and confirm they can turn around the report within 3 days of the meeting - this leaves room for the 2-working-day stock exchange deadline that applies to listed companies.
Get the explanatory statement (Section 102) vetted early for every special-business item - incomplete disclosure of a director's/KMP's interest is one of the most common grounds for members' objections.
For VC/OAVM meetings, rehearse the platform beforehand - test two-way audio-visual connectivity, screen-sharing for resolutions, and a recording/backup arrangement, since the meeting's validity depends on members being able to participate effectively.
Keep the proxy cut-off (48 hours before the meeting) visible on the notice and reminded to members - a proxy lodged late is simply invalid, which can affect quorum calculations for unlisted/private companies.
For listed companies, pre-align the e-voting period with the RTA/e-voting agency's timeline, and reconcile remote e-voting data against insta-poll data before the scrutinizer finalises the report.
Seeking confirmation for attendance from Statutory and Secretarial Auditors, Directors particularly the Chairman of Audit, Nomination and Remuneration and Stakeholder's Relationship Committee.
Alignment of speaker shareholders: understanding their concerns, past complaints, try to resolve in advance.
Liasion with Proxy Advisory firms, institutional investors: sharing rational of the resolution to enable them to support resolutions.
Timelines and selection of newspapers for publication of advertisement: has to be published minimum 21 days before AGM(in English language- in a newspaper having nationwide circulation, in Vernacular language-having wide circulation in the district where Registered office is situated).
Draft the minutes framework (agenda, expected resolutions, standard recitals) before the meeting - this keeps the mandatory 30-day signing/entry deadline comfortable rather than a scramble.
Where the AGM is likely to be adjourned (e.g., financial statements not ready for adoption), plan the AOC-4 filing sequence in advance - file the unadopted statements on time, and track the adjourned date so the second filing is not missed.
Keep a single compliance calendar that maps every post-AGM deadline (minutes, MGT-7, AOC-4, MGT-14, MGT-15, voting results, dividend payment) against the actual AGM date, not the originally planned date.
For private companies relying on the Section 179(3)/MGT-14 exemption, keep AOC-4/MGT-7 filings current - the underlying exemption notification is conditioned on the company not being in default of certain other filings, so a lapse elsewhere can put the exemption itself at risk.

What Are the Common Mistakes on AGM Compliance That Have Drawn MCA, SEBI or Stock Exchange Notices?

Holding the AGM outside the statutory window. Even where the delay is later regularised, MCA has adjudicated on it - the ROC (Delhi & Haryana) penalised Polaris India Private Limited (company ₹25,000; four directors ₹5,000 each) after its FY2020-21 AGM, due by 31 December 2021, was actually held only on 5 April 2022 - a Section 118(10) read with SS-2 para 2.1 order arising directly from the delayed AGM (Order dated 1 May 2024).
Filing AOC-4 late and treating the 30-day clock loosely. The ROC (Chennai) penalised Thirumalai Thirumal Nidhi Limited ₹37,400 each on the company and the officer-in-default for filing AOC-4 for FY2022-23 a full 274 days after the due date (Order dated 12 May 2026, Section 137(3)).
Errors in the AGM date recorded in statutory filings. The ROC (Kolkata) penalised Preet Projects Private Limited (₹10,000 company + ₹10,000 signatory officer) for entering an incorrect AGM date in Form MGT-7A - holding that an incorrect statutory filing is a completed violation even where it appears inadvertent (Order dated 19 March 2026).
Not filing MGT-14 for resolutions that require it, and letting the default run for years. MCA penalised Social Growth Nidhi Limited and four directors a combined ₹4,00,000 (the statutory maximum) after a default that ran for 2,017 days - illustrating how the ₹100/day continuing penalty under Section 117(2) compounds against a company that assumes "we will file it eventually" (Order dated 1 April 2024).
Missing the 2-working-day voting-results deadline (listed companies). BSE fined Sampann Utpadan India Limited a combined ₹47,200 (including GST) covering several SEBI LODR defaults, among them Regulation 44(3) - late submission of AGM voting results, fined at ₹10,000 per instance of non-compliance - alongside board-meeting-intimation and financial-results delays (Notice dated 14 December 2023). SEBI's Master Circular (11 November 2024) puts Regulation 44(3) on this fixed, per-instance fine schedule that exchanges apply automatically, without a separate adjudication process - one of the fastest-triggered penalties on the entire post-AGM checklist.
Assuming a newspaper advertisement is still required for the AGM notice itself. This was a genuine SEBI LODR requirement historically, but it no longer applies in that form - Regulation 47 today is concerned with advertising financial-results outcomes (with a QR code, since December 2024), not general-meeting notices. The operative disclosure channel for a listed company's AGM notice is the company's website (Regulation 46) and the Companies Act/SS-2 notice requirements that apply to every company.

How Does LexComply's Global Compliance Management System Help With Secretarial and Company-Law Compliance?

Entity-wise compliance calendar: GCMS auto-generates the full During-AGM and Post-AGM task list for every entity in the group - differentiated automatically by whether it is listed, unlisted public or private - instead of one generic checklist applied uniformly.
Deadline tracking from the actual AGM date: since every post-AGM deadline (MGT-7, AOC-4, MGT-14, MGT-15, voting results, minutes) runs from the date the AGM was actually held, GCMS recalculates the full chain of dependent deadlines the moment the AGM date is logged - removing the manual date-chasing behind several of the enforcement examples above.
Built-in exemption logic: GCMS flags where a private company's MGT-14 exemption, or a small company's MGT-7A eligibility, applies - and flags if the exemption is at risk because of an existing AOC-4/MGT-7 default elsewhere in the group.
Listed-entity overlay: for listed clients, GCMS layers the SEBI LODR-specific deadlines (Reg. 44(3) voting results, MGT-15, material-event disclosure) on top of the Companies Act calendar, so nothing listed-specific gets missed by a team used to unlisted timelines.
Document vault and audit trail: minutes, notices, scrutinizer's reports and filed forms are stored together with a version history - ready evidence if MCA or SEBI/exchanges ever raise a query of the kind illustrated in Section 6.
Escalation and ownership: each task (minutes, filings, dividend payment, disclosures) is assigned an owner with due-date alerts, so a delay is visible to the compliance team well before it becomes a 274-day-late filing.

Frequently Asked Questions

Is an AGM mandatory for a private limited company?

Yes. Section 96 of the Companies Act applies to every company except a One Person Company; private limited companies must hold an AGM within 6 months of the financial year-end (9 months for the first AGM) - the same statutory clock as public companies.

What is the deadline to file the Annual Return and financial statements after an AGM?

Financial statements (Form AOC-4) within 30 days of the AGM (Section 137); the Annual Return (Form MGT-7 or MGT-7A) within 60 days of the AGM (Section 92) - identical for listed, unlisted public and private companies.

Is e-voting mandatory for a private limited company?

Not in practice. E-voting is mandatory for every listed company and for any company with 1,000 or more members (Rule 20) - but a private company's membership is legally capped at 200, so it can never reach that threshold.

What extra compliance does a listed company have after the AGM that a private company does not?

Three items: filing a Report on the AGM in Form MGT-15 (Section 121), submitting voting results to the stock exchange within 2 working days (SEBI LODR Regulation 44(3)), and disclosing the AGM's outcome as a material event - none of which apply to unlisted public or private companies.

Does a private company have to file MGT-14 for board resolutions?

Generally no, for routine Board resolutions passed under Section 179(3) (borrowing, investments, loans/guarantees, etc.) - a 2015 exemption notification excuses private companies from this filing. Special resolutions passed by members, however, must still be filed on Form MGT-14 within 30 days.

Can an AGM still be held by video conferencing?

Yes. MCA's standing circular (General Circular No. 03/2025, dated 22 September 2025) permits AGMs to be held via video conferencing or other audio-visual means "until further orders," incorporating the procedural safeguards first set out in General Circular 20/2020 - but it does not extend the underlying statutory deadline to hold the AGM.

Sources

Companies Act, 2013 - Sections 96 to 122 (AGM, notice, quorum, proxies, poll, e-voting, minutes, report on AGM, annual return, filing of financial statements and resolutions), read with the Companies (Management and Administration) Rules, 2014.
ICSI Secretarial Standard-2 (SS-2) on General Meetings, issued under Section 118(10) of the Companies Act, 2013.
SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 - Regulations 42, 44, 46 and 47, and Schedule III (material events).
SEBI Master Circular for Compliance with the Provisions of SEBI LODR Regulations by Listed Entities, dated 11 November 2024 (Chapter VII-A - Standard Operating Procedure for fines on non-compliance).
MCA General Circular No. 03/2025, dated 22 September 2025 (AGM/EGM via VC/OAVM), read with General Circular No. 20/2020, dated 5 May 2020 (procedural framework).
Notification GSR 464(E), dated 5 June 2015 (exemptions to private companies, including MGT-14 filing of Section 179(3) Board resolutions).
MCA/ROC adjudication orders cited: Polaris India Private Limited (ROC Delhi & Haryana, 1 May 2024); Social Growth Nidhi Limited (1 April 2024); Thirumalai Thirumal Nidhi Limited (ROC Chennai, 12 May 2026); Preet Projects Private Limited (ROC Kolkata, 19 March 2026) - as reported via TaxGuru's coverage of the published orders.
BSE non-compliance notice to Sampann Utpadan India Limited, dated 14 December 2023 (Regulation 44(3) and other LODR defaults).

Legal Disclaimer

This article is general information on Annual General Meeting compliance under the Companies Act, 2013, Secretarial Standard-2 and the SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015, and does not constitute legal advice. Statutory provisions, rules and circulars are amended from time to time, and readers should verify the current position with the primary source or a qualified professional before acting.

Activity	Listed Company	Unlisted Public Company	Private Company
Finalising & signing minutes	Entered in the minutes book and signed by the Chairman within 30 days of the meeting's conclusion (Section 118, SS-2). Once so kept, the meeting is presumed duly called and held.	Same 30-day requirement (Section 118, SS-2).	Same 30-day requirement (Section 118, SS-2).
Circulation of AGM minutes	Circulate the AGM minutes internally as a checklist/administrative step. SS-2 does not impose a general duty to circulate AGM minutes to all members; statutory inspection and copy-on-request rights remain separate.	Same internal circulation step; no general SS-2 requirement to circulate AGM minutes to all members.	Same internal circulation step; no general SS-2 requirement to circulate AGM minutes to all members.
Preserving minutes & related records	Minutes of every general meeting preserved permanently. Supporting papers (notices, scrutinizer's report) preserved for 8 financial years (SS-2). Members may inspect free of charge; certified copies within 7 working days of a written request.	Same preservation and inspection requirements (SS-2).	Same preservation and inspection requirements (SS-2).
Filing the Annual Return (MGT-7 / MGT-7A)	Within 60 days of the AGM (Section 92). PCS certification mandatory regardless of size.	Within 60 days of the AGM. PCS certification mandatory only if paid-up capital ≥ ₹10 crore or turnover ≥ ₹50 crore; MGT-7A if a small company.	Within 60 days of the AGM. Same PCS-certification thresholds as an unlisted public company; MGT-7A if a small company.
Filing financial statements (AOC-4)	Within 30 days of the AGM (Section 137). If the AGM is adjourned before adoption, unadopted statements are filed within 30 days of the original date, and the adopted version refiled afterward with reasons for delay.	Same 30-day requirement and adjournment procedure (Section 137).	Same 30-day requirement and adjournment procedure (Section 137).
Filing financial statements in XBRL	AOC-4 XBRL applies to companies listed on Indian stock exchanges, subject to the sector exemptions for NBFCs, housing finance, banking and insurance. Check Rule 3 of the Companies (Filing of Documents and Forms in XBRL) Rules, 2015.	Required if an Indian subsidiary of an India-listed company, paid-up capital is at least ₹5 crore, turnover is at least ₹100 crore, or Ind AS applies. Exempt sectors: NBFCs, housing finance, banking and insurance. Previous XBRL coverage may require continued filing (XBRL Rules, Rule 3).	Required if an Indian subsidiary of an India-listed company, paid-up capital is at least ₹5 crore, turnover is at least ₹100 crore, or Ind AS applies. Exempt sectors: NBFCs, housing finance, banking and insurance. Previous XBRL coverage may require continued filing (XBRL Rules, Rule 3).
CSR reporting in Form CSR-2	File CSR-2 if covered by Section 135(1): net worth at least ₹500 crore, turnover at least ₹1,000 crore, or net profit at least ₹5 crore in the immediately preceding financial year. Applicability is independent of listing status (Accounts Rules, Rule 12(1B)).	Same Section 135(1) financial thresholds and CSR-2 reporting requirement; being unlisted does not exempt an otherwise covered company.	Same Section 135(1) financial thresholds and CSR-2 reporting requirement; private-company status does not exempt an otherwise covered company.
Filing resolutions (MGT-14)	Special resolutions, and Board resolutions under Section 179(3) (borrowing, investments, loans/guarantees, etc.), filed within 30 days of passing (Section 117).	Same filing requirement as a listed company - no exemption for Section 179(3) Board resolutions.	Exempt from filing MGT-14 for Section 179(3) Board resolutions (Notification dated 5 June 2015) - but special resolutions passed at the AGM must still be filed within 30 days. This exemption is conditional: it is only available to a private company that is not in default of filing AOC-4 (Section 137) or its Annual Return (Section 92); a default on either forfeits the exemption.
Report on the AGM (MGT-15)	Mandatory - filed within 30 days of the AGM (Section 121), confirming the meeting was called, held and conducted per the Act.	Not applicable - Section 121 applies only to "every listed public company."	Not applicable.
Voting results to the stock exchange	Submitted within 2 working days of the AGM's conclusion, in the SEBI-prescribed format, and also posted on the company's website (LODR Regulation 44(3)).	Not applicable - no stock exchange to report to.	Not applicable.
Disclosing the AGM outcome	AGM proceedings are a deemed material event under LODR Schedule III - disclosed to stock exchanges promptly, in practice well within the same working day.	Not applicable.	Not applicable.
Paying dividend, if declared	Paid/dispatched within 30 days of declaration (Section 127); Dividend amount to be banked in 5 days (not working); unclaimed amounts transferred to the Unpaid Dividend Account within 7 days of that window expiring.	Same 30-day payment requirement (Section 127).	Same 30-day payment requirement (Section 127).
Dividend processing exceptions	Reconcile NECS returns and cases where ECS cannot be used. Dummy MICR creation is an internal RTA/bank workflow step, where required, rather than a statutory AGM duty; it must not bypass electronic-payment or KYC requirements.	Reconcile failed electronic payments where relevant. Dummy MICR creation is only an internal processing step if required by the service provider; there is no general statutory AGM requirement to create such records.	Same internal processing step, only where relevant to the company's dividend payment arrangements; not a general statutory AGM requirement.
Dividend warrants and shareholder communications	Email electronic-payment acknowledgements and send payment-due intimations for physical folios lacking required PAN/KYC details. Such folios receive dividend electronically after the required details are furnished; warrants must not bypass this rule. Dispatch warrants only where otherwise permitted (SEBI RTA requirements).	Dispatch warrants or electronic-payment acknowledgements according to the lawful payment mode used. SEBI's listed-security PAN/KYC hold-intimation requirement does not apply merely because the company has physical shareholders.	Dispatch warrants or electronic-payment acknowledgements according to the lawful payment mode used. SEBI's listed-security PAN/KYC hold-intimation requirement does not apply merely because the company has physical shareholders.
Foreign dividend remittances	For relevant non-resident dividend remittances, coordinate tax documentation with the consultant and banker; arrange foreign demand drafts only where that mode is permitted. For remittances from 1 April 2026, use Form 145 and, where required, Form 146 (formerly 15CA/15CB), subject to Rule 220 conditions and exemptions.	Same remittance-based requirements; listing status does not determine applicability. Forms 145/146 apply from 1 April 2026, subject to the applicable conditions and exemptions.	Same remittance-based requirements; listing status does not determine applicability. Forms 145/146 apply from 1 April 2026, subject to the applicable conditions and exemptions.
IEPF-1 filing	File IEPF-1 with investor-wise Excel details when amounts are due for credit/transfer to IEPF under the applicable rules. This is triggered by the relevant transfer obligation, not automatically by every AGM (IEPF Rules, Rules 5 and 6).	Same IEPF-1 requirement where relevant amounts are due for transfer; unlisted status is not an exemption. Include the prescribed investor-wise Excel details.	Same IEPF-1 requirement where relevant amounts are due for transfer; private-company status is not an exemption. Include the prescribed investor-wise Excel details.
IEPF-2 and unpaid dividend disclosures	Where unclaimed/unpaid amounts are reportable, file annual IEPF-2 with investor-wise Excel details and publish the required information (IEPF Rule 5(8)). Separately, publish the unpaid dividend statement under Section 124(2) on the company's website, if any, and the prescribed website. These duties are not limited to listed companies.	Same reporting and publication duties where the relevant unpaid/unclaimed amounts exist; unlisted status is not an exemption. The company-website requirement is subject to having a website.	Same reporting and publication duties where the relevant unpaid/unclaimed amounts exist; private-company status is not an exemption. The company-website requirement is subject to having a website.
Filing Forms with RoC with in timeline	Company should ensure that all requisite forms/returns are filed with RoC; in case the AGM is held through VC, all resolutions to be filed with RoC along with confirmation of compliance of relevant MCA circular.	Company should ensure that all requisite forms/returns are filed with RoC; in case the AGM is held through VC, all resolutions to be filed with RoC along with confirmation of compliance of relevant MCA circular.	Company should ensure that all requisite forms/returns are filed with RoC; in case the AGM is held through VC, all resolutions to be filed with RoC along with confirmation of compliance of relevant MCA circular.
Dissemination of Information on Stock Exchange(s)	Company should ensure to file (in XBRL) outcome of the AGM with in 12 hours from the conclusion of AGM and Scrutnizer Report along with Voting Results (consolidated: E-voting and Remote E-voting) with in 2 working days Simultaneously hosting/ uploading with Depository/Company's website	Not applicable.	Not applicable.
AGM transcript	For a VC/OAVM AGM, retain the recorded transcript in safe custody and publish it on the company's website as soon as possible under the MCA VC/OAVM framework.	For a VC/OAVM AGM, retain the recorded transcript in safe custody and publish it on the company's website, if any, as soon as possible. The public-company requirement also covers unlisted public companies.	For a VC/OAVM AGM, retain the recorded transcript in safe custody. The MCA framework's public-company website-publication requirement does not apply to a private company.