DIR-3 KYC in 2026: the annual 30 September deadline is gone

The Ministry of Corporate Affairs amended Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014 through the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025. The Ministry described the change as replacing the annual KYC requirement with an abridged KYC once in three years, following a recommendation of the High Level Committee on Non-Financial Regulatory Reforms.

The test for being inside the rule is unchanged: you hold a Director Identification Number as at 31 March of a financial year. Designated partners of LLPs hold DINs too, so they are inside it.

Already late? The free ROC late fee calculator works out the MCA fees for every overdue AOC-4, MGT-7, Form 8 and Form 11.

If you completed KYC for FY 2025-26 (by 30 September 2025, or later with the fee) you have nothing to file until 30 June 2028, unless a contact detail changes. There is no DIR-3 KYC filing due on 30 September 2026. Reminders you may still be receiving from software vendors are running on the old calendar.

If your DIN has never been verified, or was deactivated for a missed KYC in an earlier year, do not wait for a cycle date. A deactivated DIN cannot sign an AOC-4, an MGT-7A, a DIR-12 or an incorporation form, and the day it is needed is the day the ₹5,000 fee stops looking optional. Check the DIN status on the MCA portal and file now.

If your DIN was allotted recently, the counting of your first cycle depends on the year of allotment. The Ministry’s help text and FAQs govern the edge cases, and we read the MCA record before advising rather than guessing from the rule text.

Under the amended Rule 12A(2), any change in a director’s personal mobile number, email address or residential address must be intimated in Form DIR-3 KYC Web within 30 days of the change, with the prescribed fee. It does not reset the three-year cycle; it sits alongside it.

This is where directors will trip. Changing a phone number, moving house, an NRI director relocating, a founder who registered the company’s office email as their own, each of these now starts a 30-day clock that nobody used to watch. Company secretaries who filed several directors under one office mailbox should fix that first: each director’s mobile and email must be personal and unique across DINs.

A timely three-yearly KYC costs nothing. A late one, or the reactivation of a DIN deactivated for non-filing, costs ₹5,000 per director under the Companies (Registration Offices and Fees) Rules, 2014: the same whether you are one day late or a year late, and with no proportionality for a five-director board, which pays ₹25,000.

The real cost is what a deactivated DIN blocks. Annual accounts and returns need a director with an active DIN to sign them, so a KYC lapse in one quarter becomes an AOC-4 and MGT-7A late-fee problem in the next. Appointments and resignations filed on DIR-12 fail. An incorporation where you are a proposed director stalls at SPICe+.

• Pull the DIN status of every director and designated partner from the MCA portal and record the date of their last KYC.
• Diarise 30 June of each person’s due year. For most boards that is 2028.
• Put a standing instruction in the board pack: any change of personal mobile, email or residential address goes to the company secretary within a week, so the 30-day intimation is never missed.
• Check that every director’s Class 3 digital signature is valid, because the day a filing is needed is not the day to discover it expired.
• Surrender DINs nobody uses any more in Form DIR-5. A dormant DIN carries the same obligations as an active one.

The amendment and the Ministry’s explanation are on the Press Information Bureau release; filings are made on the MCA portal.