Your company took an unsecured loan from a director in October, borrowed from a group company in January, and still has a bank term loan running. None of that feels like a "deposit", yet your auditor's checklist says "DPT-3 by 30 June". If nobody flags it, the first reminder can be a notice from the Registrar of Companies (ROC).
What Is Form DPT-3?
DPT-3 is titled "Return of deposits". It is filed under Rule 16 and Rule 16A of the Companies (Acceptance of Deposits) Rules, 2014, which were made under Sections 73 and 76 of the Companies Act, 2013.
Rule 16 requires every company to which the Rules apply to file DPT-3 with the ROC on or before 30 June every year, giving the position as on 31 March of that year, duly audited by the company's auditor.
An Explanation inserted in January 2019 says DPT-3 is used for a return of deposits, for particulars of transactions not considered deposits, or both, by every company other than a Government company. That second category is why most private companies file it.
The current form was substituted by G.S.R. 663(E) dated 29 August 2022 and is a web form on the MCA V3 portal. Its "Purpose of the Form" field offers four options, and you pick one:
- Return of deposit: for companies that accepted deposits.
- Particulars of transactions not considered as deposit under Rule 2(1)(c): for companies holding only exempted receipts, such as director or bank loans.
- Both of the above.
- One-time return under Rule 16A(3) of such receipts from 1 April 2014, a 2019 exercise.
Deposits vs Exempted Receipts Under Rule 2(1)(c)
Rule 2(1)(c) defines "deposit" very widely: any receipt of money by way of deposit or loan or in any other form. It then lists receipts that are not deposits, often called "exempted deposits". These are what most companies report in DPT-3.
| Receipt | Clause of Rule 2(1)(c) |
|---|---|
| Central or State Government, local or statutory authority | (i) |
| Foreign banks, foreign companies, non-residents (subject to FEMA) | (ii) |
| Loans from banking companies and co-operative banks | (iii) |
| Public financial institutions, insurers, scheduled banks | (iv) |
| Commercial paper | (v) |
| Money received from another company | (vi) |
| Share application money pending allotment | (vii) |
| Money from a director, or a director's relative in a private company | (viii) |
| Secured bonds or debentures, or ones compulsorily convertible within ten years | (ix) |
| Listed non-convertible debentures without a charge | (ixa) |
| Employee security deposit up to annual salary, interest-free | (x) |
| Business advances and performance security deposits | (xii) |
| Promoter loans brought in at a lender's stipulation | (xiii) |
| Start-up convertible notes of ₹25 lakh or more in one tranche | (xvii) |
| Money from AIFs, venture capital funds, InvITs, REITs, mutual funds | (xviii) |
Most of these exemptions come with conditions, and a receipt that fails them becomes a deposit:
- Director loans: the director must give the company a written declaration, at the time of lending, that the money is not borrowed from others. The company discloses the amount in its Board's report.
- Share application money: becomes a deposit if not allotted within 60 days and not refunded within the next 15 days.
- Advances for goods or services: the advance must be adjusted against supply within 365 days, unless it is the subject of legal proceedings.
- Promoter loans: exempt only until the bank loan that required them is repaid.
- Convertible notes: only for recognised start-ups, and the note must convert or be repaid within ten years.
For each category, the form asks for opening balance, receipts, repayments, other adjustments and closing balance for the year, plus an ageing of the closing balance (up to 1 year, 1 to 3 years, over 3 years).
Who Must File DPT-3
The Deposit Rules do not apply to banking companies, non-banking financial companies registered with the RBI, housing finance companies registered with the National Housing Bank, or companies the Central Government specifies under the proviso to Section 73(1). Government companies are carved out of DPT-3 by the Explanation to Rule 16. Every other company is in scope.
The Rules give no exemption for private companies, small companies or start-ups. What changes is the purpose you select:
- A private company cannot take deposits from the public, and the V3 form will not let it answer "Yes" to that question. It can accept deposits from its members under Section 73(2), subject to the conditions there and in the Rules.
- A private company with director loans, inter-corporate loans or bank loans but no deposits files DPT-3 with the purpose "particulars of transactions not considered as deposit".
- A company that accepted deposits files the return of deposits, or the combined option if it also holds exempted receipts.
The Rules do not expressly say whether a company with nothing to report must file a nil return. If your balance sheet shows no borrowings or advances at all, settle this with your CA or CS before the due date. For how DPT-3 fits alongside your other annual forms, see our ROC filing guide for 2026.
DPT-3 Due Date: 30 June, and the 2026 Position
The statutory due date is 30 June every year, for the position as on 31 March of that year. The V3 form accepts only 31 March as the reporting date.
In 2026, MCA's data centre was under restoration after a fire on 5 June 2026. MCA responded with General Circular No. 02/2026 dated 19 June 2026, which allowed companies to file DPT-3 for the financial year 2025-26 without additional fees up to 31 July 2026. We covered it in our news brief on the 31 July 2026 relaxation. The circular waived fees for that one year only. It did not amend Rule 16, so 30 June remains the due date.
| Return | Due date |
|---|---|
| FY 2025-26 (as on 31 March 2026) | 30 June 2026, no additional fee up to 31 July 2026 |
| FY 2026-27 (as on 31 March 2027) | 30 June 2027 |
| One-time return (2014 to 2019) | Due in 2019, now overdue if never filed |
If your FY 2025-26 return is still pending, the additional fee applies. Filed in November 2026, it is more than 90 days late whether you count from 30 June or 31 July, so the 10 times slab below applies either way.
We found no other 2026 circular on DPT-3. Before relying on any relaxation for a future year, check the circulars section of the MCA portal.
The Auditor Certificate Requirement
Rule 16 asks for the information to be "duly audited by the auditor of the company". The 2022 amendment added that a declaration to that effect is submitted by the auditor in Form DPT-3 itself. In the V3 form, the statutory auditor certifies that the amounts under "Particulars of deposits" and "Particulars of liquid assets" are correct, and signs with a digital signature and membership number.
An MCA letter to ICAI dated 24 June 2019 set out the scope. The auditor's certificate is mandatory only for a return of deposits. For particulars of transactions not considered deposits, the figures as on 31 March need not come from audited financial statements. The letter predates the 2022 amendment.
So if your company accepted deposits, book the auditor well before 30 June. If you report only exempted receipts, you can file from the books as on 31 March without waiting for the audited accounts.
The form itself is signed by a director, manager, company secretary, CEO or CFO authorised by a board resolution, using a DSC registered on the MCA portal. If yours is not registered yet, see our DSC guide for MCA filings.
DPT-3 Fees and Additional Fees on V3
The fee comes from the Companies (Registration Offices and Fees) Rules, 2014 and depends on nominal (authorised) share capital, not paid-up capital. See authorised vs paid-up capital.
| Nominal share capital | Normal fee |
|---|---|
| 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 crore or more | ₹600 |
| Company without share capital | ₹200 |
A late return pays an additional fee on top, as a multiple of the normal fee:
| Delay after due date | Additional fee |
|---|---|
| Up to 30 days | 2 times normal fee |
| 31 to 60 days | 4 times |
| 61 to 90 days | 6 times |
| 91 to 180 days | 10 times |
| More than 180 days | 12 times |
For example, a company with ₹10 lakh authorised capital pays ₹400 on time. If it files its FY 2025-26 return in November 2026, it pays ₹400 plus ₹4,000 in additional fee. The amount is small, but Section 403(2) says paying the additional fee does not remove liability for the penalty for the default.
How to File DPT-3 on the MCA V3 Portal
You need a V3 login linked to the company; see our MCA V3 login guide if you do not have one.
- Log in, go to MCA Services, then E-Filing, then Company Forms Download, and open Form DPT-3. The CIN fills in for a company user; a professional searches for it.
- Select the purpose of the form, whether the company is public or private and whether it is a Government company.
- Enter 31 March of the year as the period, then fill in the deposit details, the exempted receipts table, or both.
- Attach the documents. A return of deposits needs the list of depositors in MCA's Excel format, and a copy of the trust deed where a CHG-1 or CHG-9 SRN is given for secured deposits. You can add up to five optional attachments. Files are PDF or JPG, up to 2 MB each.
- Submit to generate the SRN, download the PDF, affix the DSCs (the authorised signatory and, where the auditor declaration applies, the statutory auditor) and upload it.
- Pay the fee. The SRN is cancelled if the signed PDF is not uploaded within 15 days of SRN generation, or if payment is not made within 7 days of that upload or by the due date plus 2 days, whichever is earlier.
A return of deposits, alone or combined, goes to the ROC for review (non-STP). A filing of only exempted receipts is taken on record electronically (STP mode) with no resubmission, so check every figure before you sign.
Penalty for Not Filing DPT-3
Rule 21 of the Deposit Rules covers contraventions of the Rules for which the Act provides no punishment. It is worded for companies taking member deposits under Section 73(2), eligible companies and "any other person", and allows a court fine of up to ₹5,000, plus up to ₹500 a day while the contravention continues.
ROCs have adjudicated DPT-3 defaults under Section 450, the Act's general penalty provision. Since 21 December 2020, it provides a penalty of ₹10,000, plus ₹1,000 for each day after the first that the contravention continues, up to ₹2,00,000 for the company and ₹50,000 for each officer in default. On 22 April 2026, ruling on the company's own application, the ROC Hyderabad imposed ₹10,000 each on a company and its director for a one-time DPT-3 return due in 2019.
Under Section 446B, One Person Companies, small companies, start-ups and producer companies, and their officers, are liable to no more than half of a penalty under the Act, subject to a ceiling of ₹2 lakh for the company and ₹1 lakh for an officer.
The filing default is the smaller risk. A receipt outside Rule 2(1)(c) is a deposit, and accepting deposits in breach of Chapter V carries far heavier consequences. Under Section 76A, the company repays the deposit with interest and faces a fine of at least ₹1 crore (or twice the deposit, if lower), up to ₹10 crore. Each officer in default faces up to seven years in prison and a fine of ₹25 lakh to ₹2 crore. Getting the classification right matters more than the late fee.
Before You File: A Quick Checklist
- List every loan, advance and receipt outstanding at any point in the year, not just the 31 March balances.
- Map each one to a clause of Rule 2(1)(c), or treat it as a deposit.
- For inter-corporate loans, confirm the lender is a company. You can look up its CIN and status on WeeDoo's company search.
- For director loans, confirm the person was a director on the date the money came in, using WeeDoo's director search, and keep the signed declaration on file.
- Check that trade advances older than 365 days have been adjusted or refunded.
Frequently Asked Questions
What is the due date for DPT-3?
30 June every year, with figures as on 31 March. For FY 2025-26, General Circular 02/2026 allowed filing without additional fees up to 31 July 2026. The return for 31 March 2027 is due by 30 June 2027 unless MCA relaxes it again.
Is DPT-3 mandatory for private limited companies?
Yes, if it has deposits or exempted receipts such as director, inter-corporate or bank loans. Private companies are not exempt and usually file the "particulars of transactions not considered as deposit" purpose.
Do loans from directors need to be shown in DPT-3?
Yes. A loan from a director, or from a director's relative in a private company, is an exempted receipt under Rule 2(1)(c)(viii), provided the director gives a written declaration that the money is not borrowed. It is reported in the exempted receipts table of DPT-3.
Is an auditor certificate required for DPT-3?
Only for a return of deposits, per MCA's letter of 24 June 2019. The V3 auditor declaration covers the deposit and liquid asset figures. Under that letter, a company reporting only exempted receipts does not need it.
What is the late fee for DPT-3?
An additional fee of 2 to 12 times the normal fee of ₹200 to ₹600, depending on the delay. Paying it does not cure the default: the company and its officers can still face a penalty under Section 450, or a fine under Rule 21.
