MCA21 V3 Portal Glitches: ICSI Urges MCA to Extend Filing Deadlines & Waive Additional Fee for Sept–Dec Forms

In a letter dated September 29, 2025 to Secretary Deepti Gaur Mukerjee, ICSI President CS Dhananjay Shukla has stated that the transition from MCA-21 V2 to V3, while deployed with the intention to improve ease of doing business, has inadvertently left professionals unable to file numerous e-forms, prompting requests for practical relief and speedy resolution.

Following is the detailed list of forms and the corresponding issues that are faced by professionals as highlighted by ICSI in the letter to the Ministry.

DIR-3 WebKYC: Difficulty in generating OTPs in case of foreign nationals leading to non-compliance. The newly added IVR facility is also not functioning well as per the feedback received.

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Incorrect Prefilled: During the filling of form users are facing issue where details are incorrect in prefilled data.

Upon inserting SRN of approved RUN form - data of some other company is being re-filled or is incorrect.

Unable to Save and Submit: Users are unable to complete the filing process when at the last moment error occurs: "Validation Error: Submission Restricted".

MCA System is not allowing to proceed further to save Form and affix DSC. Error occurs during 'Save and Submit'.

Master Data not Updated: After processing and submission of Form PAS-3/CRF etc., even after where the Forms are approved, the same is not reflected in the MCA master data.

Unable to upload form after affixing DSC: Even while DSC is being correctly affixed and registered on MCA portal as well, at the time of uploading the eform after affixing the DSC following error is occurring: "DSC Verification Failed".

Login Issue: Unable to reset password: Taking the route of 'Forgot Password' where a user tries to continue by clicking on "Proceed Button" the following error message appears: "Something went wrong. Please try again later".

Profile not updated: Wherein professionals are adding their current role in the User profile the same is not updated and old role is visible in the user ID.

Unmasking/unhiding particulars of form till it is filed and submitted: In forms like DIR-12, DIR-3, DIR-3 KYC etc., few details in particular forms are filled and gets masked/or hidden during the submission process itself.

This makes it impossible to verify the said particulars before filing.

Acceptance and Confirmation is being asked for users' details which have been marked with asterisks.

It is requested to mask/hide details only after filling or submission of the form.

Time bound Approval of Forms: For the purpose of compliance of certain provisions and filling of forms appurtenant thereto, prior approvals of other forms is required. Such forms may not be approved even after 30 days which is usually the period within which the next form is required to be filed.

It is requested to kindly advise upon time bound approval of Forms.

Minimise use of Captcha: In order to view basic company Master Data on MCA portal, captcha is required to be provided 2 times and in case of Director Master Data, it is required to be provided 3 times, which takes unnecessary time of the user.

It is suggested to minimise the use of captcha while using the MCA website.

Option to Save data of Forms may be provided: Various E-forms may not be completed in one go and require multiple revisits for filling of information.

In such a situation, it becomes difficult for the professional to go back and forth with the directors or promoters of the Company to take OTP sent to them.

It is suggested to make provisions to save the data on the first OTP compliance and to process further without having to re-fill same details in the Form.

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Resubmission date to be made available: In case of forms requiring resubmission, the date of resubmission may be mentioned in the remark column.

Also, issues have been faced where Resubmission remarks are not visible.

Downloading issues: After submission of the form, when user tries to download the said form, in some cases only attachments are getting downloaded & in some cases other company's forms are getting downloaded especially in case of linked forms.

This causes delay in filing forms, due to which user is unnecessarily burdened with additional fees.

Certificate generation issues: Sometimes Certificates are not getting generated after approval of the forms & sometimes Certificates are generated with incorrect details.

Attachment size issue: In some forms, even attachments are less than 10MB, it throws error that "The total size of all attachments should not be more than 10MB". System capacity need to be improved.

Maximum size of List of shareholders is 300 MB but in companies there are numerous shareholders so the stakeholders are not able to provide the details of all shareholder due to the 300MB size issue.

Information related issues: In some forms, stakeholders have been asked to provide additional details like in form MGT-7 for example list of shareholders with Gender bifurcation details which are not available even with RTA's. Form is also asking for date of incorporation of Foreign Institutional Investor (FII).

ICSI has further highlighted that the Central Board of Direct Taxes had already extended the tax audit report deadline to October 31, 2025.

In light of the various issues, including persistent glitches faced by multiple stakeholders, the ICSI has presented its requests, alluding to the inability of professionals to effectively render their duties.

Accordingly, ICSI requested that:

i) Annual filing forms - AOC-4 CFS NBFC (Ind AS), AOC-4(XBRL), AOC-4, AOC-4(CFS), AOC-4 NBFC (Ind AS), MGT-7 and MGT-7A be extended to December 31, 2025 without the levy of additional fees

ii) Relaxation in levy of additional fees for all forms that are due between September 1 and December 31, 2025.

The ICSI has reaffirmed its willingness to provide any further information or clarification that the Ministry of Corporate Affairs might require to make requisite changes in response to the issues faced by professionals.

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