File INC 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.
To file INC-22A (ACTIVE), attach an exterior and interior photo of the registered office with a signing director/KMP, enter the company's directors, auditor (ADT-1), KMP and email details, verify by OTP, affix DSCs of a director and a practising professional, and submit on the MCA portal.
Overview
Form INC-22A, called ACTIVE (Active Company Tagging Identities and Verification), was introduced to verify that companies operate from a genuine registered office. It is essentially a KYC of the registered office and the company's key details. Filing it keeps the company's status as "ACTIVE Compliant" on MCA records.
When It Is Required & Legal Basis
Rule 25A of the Companies (Incorporation) Rules, 2014 requires every company incorporated on or before 31 December 2017 to file INC-22A. Companies that are struck off, under process of striking off, amalgamated, dissolved or under liquidation are excluded. A company that has not filed its due AOC-4 and MGT-7 cannot file INC-22A unless it is under management dispute recorded by the ROC.
Step-by-Step Process
- Check eligibility. Confirm the company was incorporated on or before 31 December 2017 and that all overdue annual filings (AOC-4, MGT-7) are completed.
- Verify director KYC. Ensure all directors have valid DINs with completed DIR-3 KYC; disqualified/deactivated DINs must be resolved first.
- Take photographs. Capture an external photograph of the registered office building and an internal photograph showing at least one signing director/KMP inside the office, with the name board visible.
- Fill the form. Enter details of directors, statutory auditor (with SRN of ADT-1), cost auditor if applicable, KMP, and a company email for OTP verification.
- OTP verification. Verify the email ID entered in the form through the OTP sent to it.
- Affix DSCs. Sign with the DSC of one director (and KMP where applicable) and certify by a practising CA/CS/CMA.
- Submit and pay. Upload on the MCA portal and pay the fee (nil if within due date, ₹10,000 if late).
Forms, Attachments & Fees
| Item | Detail | Remarks |
|---|---|---|
| Form | INC-22A (ACTIVE) | Rule 25A |
| Exterior photo | Building with name board and address | Mandatory |
| Interior photo | Office with a signing director/KMP | Mandatory |
| Fee (on time) | Nil | — |
| Fee (late) | ₹10,000 | Plus ACTIVE-non-compliant tag |
The form also captures the number of directors, details of the statutory auditor and the SRN of the latest ADT-1, KMP details for companies required to appoint them, and the company's registered email ID.
Timeline & Due Dates
The form is filed once as a compliance verification; there is no recurring annual due date, but eligible companies that never filed it should file immediately to clear the ACTIVE-non-compliant tag. Filing takes effect on approval, and the status changes to ACTIVE Compliant.
Penalty for Delay / Non-compliance
Late filing attracts a fee of ₹10,000. More importantly, until INC-22A is filed the company is marked "ACTIVE-non-compliant", and the ROC will not record several event-based changes — SH-7 (change in authorised capital), PAS-3 (allotment of shares), DIR-12 (changes in directors other than cessation due to death or disqualification), INC-22 (change of registered office) and INC-28 — blocking normal corporate actions.
Practical Tips
- Clear all pending AOC-4 and MGT-7 filings first — INC-22A will not accept a company with overdue annual filings.
- Make sure the ADT-1 for the statutory auditor has been filed; the SRN is required in the form.
- Have the signing director physically present at the registered office for the interior photograph.
- Complete DIR-3 KYC for all directors before filing so no DIN is deactivated.
ACTIVE-Compliant vs ACTIVE-Non-Compliant
The whole purpose of INC-22A is to tag a company's identity as either "ACTIVE Compliant" or "ACTIVE Non-Compliant" on MCA records. A company that files the form correctly and on time carries the "ACTIVE Compliant" status and continues to make event-based filings without interruption. A company that has not filed it, or filed it after the due date without paying the late fee, is marked "ACTIVE Non-Compliant", and the practical fallout is significant: the ROC will not register several important changes until the tag is cleared. Specifically, filings for change in authorised capital (SH-7), further issue/allotment of shares (PAS-3), changes among directors other than cessation on account of death or disqualification (DIR-12), change of registered office (INC-22), and amalgamation/demerger orders (INC-28) are all blocked. This can stall a funding round, a board reshuffle or an office relocation at short notice. Clearing the tag simply requires filing INC-22A with the ₹10,000 late fee, after which the status flips back to "ACTIVE Compliant" and the blocked filings become available again. Because the trigger for eligibility is incorporation on or before 31 December 2017, older companies that never filed the form should treat it as an outstanding one-time compliance and clear it before attempting any of the blocked filings.