What changed on 31 March 2026?
Director KYC is an obligation of the individual DIN holder. It does not depend on whether the person is currently a director, holds an executive or nominee role, lives overseas, or has never used the number. Designated partners using a DIN must also keep it compliant. Disqualification under section 164 and deactivation for KYC default are separate; bringing KYC up to date does not lift a disqualification.
G.S.R. 943(E) replaced annual Rule 12A with periodic KYC intimation on the MCA portal. Under amended Rule 12A(1), a person holding a DIN as at 31 March must file Form DIR-3-KYC-Web by 30 June immediately following every third consecutive financial year. MCA announced 30 June 2028 as the next filing date for the cohort that had already completed KYC at the transition. For a newly allotted, previously deactivated or recently reactivated DIN, check its allotment history, status and applicable cycle; do not assume that the published transition date cures an existing default or applies to every later allotment.
Rule 12A(2) separately requires an update within 30 days when the holder changes their personal mobile number, email address or residential address. For example, for a change on 10 August 2026, the 30th day is 9 September 2026. The published transition date does not postpone this obligation.
Which filing option and fee apply now?
| Purpose | What to do | Government fee under the amended schedule |
|---|---|---|
| Periodic KYC on time | Select KYC compliance in DIR-3-KYC-Web. Validate the required OTPs; no director DSC or professional certification for a confirmation without changes. | Nil |
| Overdue periodic KYC or reactivation after KYC default | Use the purpose that matches the DIN's status. Submit the form, pay the applicable fee and verify that MCA records the updated status before relying on it. | ₹5,000 for late filing or reactivation under item VII(ii). |
| Change to personal mobile, email or permanent/present residential address | Use the relevant change option in DIR-3-KYC-Web within 30 days, supply the relevant evidence and authentication and obtain the holder's DSC and certification by an eligible practising professional. | ₹500 per filing when the form is filed again for a Rule 12A(2) change. Two such separate change filings cost ₹1,000. |
| Name, date of birth, nationality or other DIN master particulars outside Rule 12A(2) | Check the applicable DIR-6 change process and supporting evidence. Where a DIN change falls under Rule 12, the ordinary intimation period is 30 days. | Follow the rules for the applicable form. |
The fee rules apply from publication of G.S.R. 300(E) in April 2026. The ₹5,000 is a filing fee, not a daily penalty. For DIN deactivated due to KYC, Rule 11(3) requires the form and prescribed fee for reactivation. Check the reason shown: the KYC route does not remedy a cancellation, disqualification or other independent restriction.
How to submit and confirm the filing
- Find the current DIR-3-KYC-Web service on MCA21 V3. Confirm the DIN and the stated purpose before generating authentication codes.
- Use the holder's personal mobile number and email. Keep both channels accessible. For a change filing, follow the current screen for the OTP, address evidence where applicable, and digital signatures. Use the appropriate country code for a foreign mobile number.
- Save the service request number (SRN), payment receipt if applicable and submission confirmation. Check the DIN status on MCA after processing; no fixed reactivation time is guaranteed.
Foreign citizens and non-resident Indian citizens should follow the instructions for their own citizenship, PAN and passport status. In the old full form, an Indian citizen was required to enter PAN; a foreign citizen had to provide passport details and enter PAN if held. The old kit allowed alternative identity documents where the applicant did not have Aadhaar. For an overseas proof submitted now, use the current form's instructions for acceptable evidence, translations and any authentication required for the issuing jurisdiction. Do not carry over old document or apostille requirements to an unchanged periodic confirmation.
How the old annual process worked
Before 31 March 2026, the ordinary test was whether the DIN was held on 31 March and the due date was 30 September of the next financial year. The first filing or a mobile/email change ordinarily used the full DIR-3-KYC form with the holder's and practising professional's digital signatures. Repeat holders with no changes could use DIR-3 KYC-WEB with OTP authentication. For an address or other master-data change, the applicable DIR-6 process was separate. The ordinary filing was free when on time; a DIN deactivated for non-filing required a ₹5,000 overdue KYC filing. These historical rules remain relevant to interpreting an earlier default.
| DIN position | Obligation by 30 September 2025 | What to check next |
|---|---|---|
| Held before April 2024, prior KYC and unchanged details | Repeat annual web confirmation. | If compliant at transition, MCA's next periodic date is 30 June 2028. |
| Allotted 15 November 2024 or 31 March 2025 | First annual KYC under the old full-form route. | If missed and DIN deactivated, file for reactivation. |
| Allotted 1 April 2025 | No obligation in the September 2025 round. | Do not schedule September 2026 using the superseded annual rule; check the amended cycle. |
| Already deactivated for a 2024 default | Resolve the outstanding KYC default. | A KYC cycle change does not reactivate the DIN. |
Six worked filing situations
1. Two founders receive DINs just before the 2025 cutoff
NextGen incorporates on 30 March 2025, when both founders receive DINs. Both held DINs on 31 March, so the first historical KYC was due 30 September 2025, regardless of the company's first financial year. If both DINs are deactivated for missing it, the two overdue filings cost ₹5,000 each, or ₹10,000. The company's separate 180-day INC-20A period ended on 26 September 2025. Finding the DIN issue on 5 October cannot save that original deadline; address the late commencement filing separately.
2. Five different positions on the same board in 2025
| Director | Historical action for the 2025 round | Ordinary KYC fee if timely |
|---|---|---|
| 1: unchanged since a full 2021 filing | Repeat web KYC with OTPs. | Nil |
| 2: full KYC in 2022, new personal mobile in May 2025 | Use the full form to update the mobile number, with OTP and the required DSCs. | Nil for the ordinary timely filing; a repeat change filing could separately attract a fee. |
| 3: DIN allotted 10 December 2024 | Full first KYC with the required documents and DSCs. | Nil |
| 4: full KYC in 2020, changed home address in June 2025 | Notify the address change through the historical DIR-6 process within the applicable 30 days. Complete annual KYC using the route available for the corrected record. | Nil for the timely periodic KYC. |
| 5: DIN allotted 12 April 2025 | Outside the September 2025 round. | No filing for that round. |
3. A director's DIN is deactivated near the AOC-4 deadline
OmniLogistics held its AGM on 30 September 2025. Its ordinary section 137 filing period of 30 days ran to 30 October 2025. If it finds a deactivated signatory DIN on 28 October, verify the form's authorised signatory and promptly file overdue KYC if that director's signature is needed. In the example the director pays ₹5,000 under the then-applicable schedule. Confirm reactivation and the AOC-4 submission separately. The requirements for signing financial statements under section 134 are distinct from the signatory requirements on the AOC-4 webform.
4. First filing by an overseas director under the old full-form process
A director in Munich with a January 2025 DIN submits a German passport scan and a German utility bill. Before filing, obtain the identity and address evidence required under the applicable form instructions, an acceptable English translation where needed, and authentication if required for the document and issuing jurisdiction. Do not assume every utility bill must be apostilled under Rule 12A, or that one missing authentication automatically results in prosecution or DIN deactivation.
5. A PAN verification mismatch
A DIN shows “R. K. Sharma” while the PAN record shows “Rajesh Kumar Sharma”. Verify which record is wrong, correct that record through the relevant authority, and use DIR-6 if the DIN name needs correction. Provide the required identity and change evidence, wait for the corrected record to appear, then retry any outstanding KYC. A name error is not an address or contact update under amended Rule 12A(2).
6. Several missed annual cycles on one DIN
Kavita missed five annual KYC rounds from FY 2019–20 to FY 2023–24. Under the historical reactivation workflow in November 2025, the ₹5,000 charge applied to the overdue reactivation filing, so the calculation was ₹5,000 for one such filing, not ₹25,000 for five missed years. If she is still deactivated due to KYC, she should now use the current form's reactivation purpose and check the reason and status after payment. Reactivation does not erase the history or remedy other defaults.
Internal controls and common questions
- Track people and deadlines separately. Record each DIN, its KYC and status history, the applicable 30 June year, and any changes that start a separate 30-day clock. Check the relevant dates before filings that depend on a director's DIN.
- Can spouses share OTP details? Each holder should provide their own personal mobile and email as required by the form. For a delivery failure, verify the country code, SIM, inbox and spam folder, and follow the portal resend or helpdesk instructions. Do not share OTPs with third parties.
- Can a disqualified director file KYC? KYC is a separate obligation. A compliant DIN does not entitle a disqualified person to serve or sign where independently barred.
- Can an unused DIN be surrendered? Rule 11 allows an application in DIR-5 where the DIN holder has never been appointed as a director in any company and the DIN has not been used to file a document with an authority. The authority verifies eligibility; the application alone does not cancel the DIN.
- Who certifies a change filing? Arrange certification by another eligible professional in practice where the holder is themselves a practising professional. The holder signs in the applicant's capacity.
Sources
- G.S.R. 943(E), 31 December 2025: Rules 11 and 12A and the notified DIR-3-KYC-Web form
- G.S.R. 300(E), 21 April 2026: registration office and filing fee amendment
- MCA transition guidance on the 30 June 2028 deadline
- MCA DIR-3-KYC instruction kit for the earlier annual workflow
- MCA DIR-6 instructions: changes to DIN particulars
- MCA INC-20A instructions: commencement declaration and time limit
- Companies Act, 2013: DIN framework and financial statements