Form DPT explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
DPT-3 is the most-skipped annual filing in India, and it's the name's fault.
Companies read "return of deposits", think "we've never taken a deposit", and don't file.
But the form does two jobs. It reports deposits — and it separately reports money you received that isn't a deposit. Director's loans. Share application money. Customer advances. Loans from other companies. Bank borrowings.
Almost every operating company has something in that second list sitting on its books at 31 March.
Due 30 June every year, for balances as on 31 March. Every company except a Government company. The one document that decides whether a director's loan is a deposit or not is a written declaration from that director — get it signed when the money arrives, not in June.
What does Rule 16 actually say?
Every company other than a Government company must, on or before 30 June each year, file a return in Form DPT-3 with information as on 31 March of that year, duly audited by the company's auditor.
And the Explanation to Rule 16 removes any argument: the return covers deposits or outstanding receipt of money or loan not considered as deposits under Rule 2(1)(c).
| Must file | Every company — private, public, OPC, small, Section 8 — holding, at 31 March, any outstanding deposit or any receipt not considered a deposit |
| Exempt | Government companies (and, in practice, a company with genuinely nil balances in both) |
| Due | 30 June, for balances at 31 March |
| Auditor's certificate | Required where deposits are reported |
A dormant company, or one that hasn't commenced business, still files if it's holding a director's loan.
What isn't a deposit?
Section 2(31) defines "deposit" broadly — any receipt of money by way of deposit or loan or in any other form — then excludes what's prescribed. Rule 2(1)(c) holds the exclusion list. The ones that matter to a private company:
| Excluded receipt | Condition |
|---|---|
| From Central or State Government, or a local authority | — |
| From foreign governments, foreign banks, foreign collaborators, foreign bodies corporate and citizens | Subject to FEMA |
| Loan from a banking company or co-operative bank | — |
| Loan from a Public Financial Institution, insurance company or scheduled bank | — |
| Against issue of commercial paper | — |
| From any other company (inter-corporate) | — |
| Share application money | Allotment within 60 days; if not allotted and not refunded within 15 days after, it becomes a deposit |
| From a director | Only with a written declaration that the money isn't itself borrowed. Disclose in the Board's Report. |
| From a relative of a director — private companies only | Same written declaration; same disclosure |
| Against secured bonds or debentures compulsorily convertible within 10 years | — |
| Employee security deposit | Non-interest-bearing, not exceeding annual salary, under the employment contract |
| Advance for goods or services | Appropriated within 365 days of acceptance |
| Advance for immovable property | Adjusted against the property under an agreement |
| Advance as security deposit for performance of a supply contract | — |
| Advance under a long-term project for capital goods | — |
| Received by a start-up as a convertible note | Single tranche of ₹25 lakh or more, convertible or repayable within 10 years |
| From a registered AIF, VCF, InvIT, REIT or Mutual Fund | — |
The two conditions that trip people up:
The director's loan declaration. No declaration on file, and that loan is a deposit. Which means Section 73 applies, which means Section 76A exposure — a minimum ₹1 crore on the company and imprisonment up to seven years for officers in default. For a loan the founder put in to cover salaries.
Share application money. Not allotted within sixty days, not refunded within a further fifteen — it becomes a deposit from the expiry of those fifteen days. The same consequences follow.
What goes into the form?
You first elect the purpose — return of deposits only, non-deposit receipts only, both, or the outstanding position at 31 March.
Then, as at 31 March:
- Net worth per the latest audited balance sheet;
- Total deposits outstanding, category-wise;
- Total receipts not considered deposits, broken up by Rule 2(1)(c) category — director's loans, inter-corporate borrowings, bank borrowings, customer advances, share application money and so on;
- Credit rating, charge and deposit insurance particulars, where deposits are held;
- Liquid assets particulars, where deposits are held.
Attach: the auditor's certificate (mandatory where deposits are reported), the list of depositors where applicable, the trust deed, charge instrument and insurance contract where applicable — and, usefully, a working of your "not considered as deposits" figures.
What does it cost to get wrong?
Normal fee on the nominal-capital slab, ₹200 to ₹600, with additional fee on the usual 2× to 12× delay slab.
For not filing, adjudication runs under Section 454 with Section 450 as the fallback penalty: ₹10,000 plus ₹1,000 a day, capped at ₹2,00,000 for the company and ₹50,000 for an officer.
For money that turns out to be a deposit accepted in breach of Section 73, the picture changes completely. Section 76A:
- the company — a minimum of ₹1 crore or twice the deposits accepted, whichever is lower, up to ₹10 crore;
- every officer in default — imprisonment up to 7 years and a fine of ₹25 lakh to ₹2 crore.
Which is the real point of this article: the classification exercise matters far more than the filing. Deposits from members, in full →
Filing checklist
- Pull the trial balance at 31 March and list every credit balance representing money received.
- Classify each against the Rule 2(1)(c) list.
- For every director's loan, confirm a written declaration is on file, dated on or before receipt.
- For relatives of directors (private companies only), confirm the same declaration.
- For share application money, apply the 60-day allotment and 15-day refund tests.
- For customer advances, apply the 365-day appropriation test.
- Anything failing a test is a deposit — deal with the Section 73 consequences before you file, not after.
- Get the auditor's certificate where deposits are reported.
- Confirm the Board's Report discloses the director and relative loans, as Rule 2(1)(c) requires.
- File by 30 June, keep the challan.
Key takeaways
- DPT-3 is not just about deposits. If you have a director's loan at 31 March, you file.
- The director's declaration is the whole ballgame. Get it signed when the money comes in.
- Share application money has a 60 + 15 day fuse. After that it's a deposit.
- The relative-of-a-director exclusion is private-company-only.
- Customer advances must be appropriated within 365 days.
- Section 76A starts at ₹1 crore and includes imprisonment. Classify carefully.
Read next
- Annual Compliance Calendar for Private Companies
- Accepting Deposits from Members: Sections 73–76A
- Exemptions and Carve-Outs for Private Companies
- Penalties for Non-Compliance: Section-wise Chart
Disclaimer: Positions stated as on 4 September 2026. The Deposit Rules are amended often and the exclusion list is detailed and condition-bound — classify with professional advice before filing.