DPT-3 Filing — Annual Return of Deposits and Outstanding Loans
DPT-3 is the annual return in which a company tells the Registrar what money it is holding that came in from outside its share capital. It is filed under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014, read with section 73 of the Companies Act, 2013, and it reports balances as at 31 March. The base due date is 30 June each year.
Most founders assume it does not apply to them because they have never taken a deposit. That is the single most expensive misconception in this area. The return covers not only actual deposits but also the long list of receipts that are specifically excluded from the definition of a deposit — director loans, inter-corporate loans, bank and financial institution borrowings, money from shareholders of a private company, security deposits, and customer advances. If any of those is outstanding on 31 March, the company files.
This guide covers who must file, what counts as a reportable receipt, the difference between the deposit and exempted-deposit purposes of the form, when an auditor’s certificate is needed, the documents and figures required, the filing steps, indicative fees and the additional-fee slab for delay, and what non-filing actually exposes the company and its officers to.
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What is Form DPT-3?
DPT-3 is the "Return of Deposits" prescribed under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. It is an annual disclosure to the Registrar of Companies of deposits held by the company and of amounts received by way of loan or otherwise that the rules do not treat as deposits, as they stood on 31 March of the financial year.
Its purpose is supervisory. Chapter V of the Companies Act tightly restricts a company’s ability to take money from the public, and the exemptions in Rule 2(1)(c) are what make ordinary business borrowing possible. DPT-3 is how the Registrar sees, once a year, that the money sitting on a company’s balance sheet under "unsecured loans" and "advances" is genuinely inside those exemptions.
It is a company filing, not a director filing, and it is separate from the annual return and financial statements filed under company annual filing. A company can be fully current on AOC-4 and MGT-7 and still be in default on DPT-3.
Who has to file DPT-3?
Every company registered under the Companies Act that has any reportable outstanding amount as on 31 March, subject to a short list of exclusions. Turnover, profitability, and activity level are irrelevant.
- Private limited companies, including those with no revenue
- Public limited companies, listed and unlisted
- One Person Companies — see OPC compliance
- Section 8 companies and Nidhi companies
- Small companies and startup companies
- Companies holding only a director’s loan and nothing else
- Companies holding only a bank term loan or working-capital facility
- Companies with share application money pending allotment beyond the permitted period
Generally outside the requirement: government companies, banking companies, non-banking financial companies registered with the RBI, and housing finance companies registered with the National Housing Bank. LLPs are not covered at all, because the deposit rules sit in the Companies Act — an LLP’s obligations are the ones described in LLP annual filing.
Where a company genuinely has nil outstanding on 31 March — no loans, no advances, no deposits, nothing but share capital and trade payables — the return is not called for. That is a conclusion to reach from the balance sheet, not an assumption, because the reportable list is wider than most founders expect.
What amounts have to be reported in DPT-3?
Two buckets: actual deposits accepted under Chapter V, and the receipts that Rule 2(1)(c) excludes from the definition of a deposit. The second bucket is where almost every ordinary company finds itself.
- Loans from directors, out of their own funds, with the required declaration on record
- Loans from members or shareholders of a private company, within the applicable conditions
- Inter-corporate loans received from another company
- Term loans, working-capital facilities, and overdrafts from banks
- Loans from public financial institutions, insurance companies, and scheduled banks
- Money received from a foreign body corporate or a person resident outside India under FEMA
- Share application money pending allotment, where allotment has not happened within the permitted period
- Security deposits taken from employees, within the prescribed limits
- Advances received from customers against supply of goods or provision of services, within the conditions on their use and refund
- Amounts raised by issue of secured bonds or debentures, and certain compulsorily convertible instruments
- Money received from a promoter by way of unsecured loan in fulfilment of a lending stipulation
Report the principal plus accrued interest, categorised by the exemption it falls under. Two traps recur. A customer advance stops being an exempt receipt if it is not applied to the supply, or not refunded, within the period the rules allow — at which point it becomes a deposit with all the Chapter V consequences. And share application money that has been sitting pending allotment past its window is reportable, which is the most common finding in a startup that raised money late in the financial year.
What is the difference between a deposit and an exempted deposit?
| Aspect | Actual deposit (Chapter V) | Exempted receipt under Rule 2(1)(c) |
|---|---|---|
| Typical source | Members or public under an approved deposit scheme | Directors, shareholders of a private company, banks, other companies, customers |
| Who may accept | Eligible companies, subject to conditions and approvals | Any company, within the conditions of the specific exemption |
| Auditor’s certificate in DPT-3 | Required | Generally not required |
| Source of figures | Duly audited financial statements | Need not be from audited statements, per MCA clarification |
| Supporting documents | Trust deed, charge instrument, list of depositors | Normally none beyond internal records |
| Typical private-company case | Rare | The usual position |
MCA clarified in 2019 that the auditor’s certificate under Rule 16 is mandatory only in the case of a return of deposits, and that where a company is reporting only particulars of transactions not considered as deposits, the information need not come from duly audited financial statements. That clarification is what makes the 30 June date workable — an audit is often not complete by then, and it does not need to be for an exempted-deposit return.
The form asks you to choose a purpose, and choosing wrongly is a real risk. Selecting a deposit purpose when you only hold a director’s loan triggers a demand for an auditor’s certificate you do not need; selecting the exempted purpose when you have accepted actual deposits understates a serious obligation.
When is DPT-3 due?
Rule 16 fixes the return on or before 30 June of every year, reporting the position as on the preceding 31 March. That date is stable in the rules. What moves is whether MCA grants relief in a particular year.
For FY 2025-26, MCA extended the DPT-3 due date from 30 June 2026 to 31 July 2026 without additional fees, by General Circular No. 02/2026 dated 19 June 2026, following the fire at the MCA data centre on 5 June 2026 and the restoration work that followed. Filings made after the extended date attract additional fees in the normal way.
Treat any such extension as year-specific. We confirm the operative date against the current circulars before filing rather than carrying last year’s relief forward, because an extension in one year creates no expectation in the next.
What documents and figures are required for DPT-3?
- CIN, to pre-fill company particulars on the portal
- Net worth figures as at 31 March, from the audited accounts where available or the latest available accounts otherwise
- Category-wise outstanding balances — principal plus accrued interest — for each exemption relied on
- Total outstanding money or loans not treated as deposits
- Particulars of deposits accepted, matured, repaid, and outstanding, where actual deposits exist
- Auditor’s certificate, where the return reports actual deposits
- Credit rating, where the company has accepted deposits and a rating is required
- Copy of the trust deed and the charge instrument, where secured deposits exist
- List of depositors, where applicable
- Board resolution or authorisation for the signatory
- Valid Class 3 DSC of an authorised director or the company secretary
The practical work is the categorisation, not the filing. Most trial balances lump everything into "unsecured loans", and the return needs it split by exemption with interest accrued to 31 March. We reconcile the ledgers to the balance sheet before opening the form, because a figure that does not tie to the financial statements filed later is the kind of inconsistency that invites a query.
How to file DPT-3 online?
- 1.Extract every loan, advance, deposit, and application-money balance as at 31 March
- 2.Classify each balance against the specific exemption in Rule 2(1)(c) it relies on
- 3.Compute accrued interest to 31 March for each category
- 4.Confirm whether any balance is an actual deposit, which changes the purpose and the attachments
- 5.Compute the net worth figures the form requires
- 6.Obtain the auditor’s certificate where actual deposits are being reported
- 7.Log in to MCA V3 as a business user with the signatory’s DSC associated
- 8.Open Form DPT-3 under company e-filing and enter the CIN to pre-fill
- 9.Select the correct purpose — for most private companies, the return of particulars of transactions not considered as deposits
- 10.Enter the net worth and category-wise outstanding amounts
- 11.Attach the auditor’s certificate, trust deed, or list of depositors only where they apply
- 12.Affix the DSC, submit, and pay against the SRN promptly
Pay the same day you submit. An SRN left unpaid does not count as a filing, and a company that submitted on the due date but paid two days later is late.
How much does DPT-3 cost to file?
The normal fee follows the standard e-form slab linked to authorised share capital under the Companies (Registration Offices and Fees) Rules, 2014. Late filing attracts a multiplier on that normal fee rather than a per-day amount.
| Element | Basis | Indicative amount |
|---|---|---|
| Normal filing fee | Slab on authorised share capital | A few hundred rupees for most small companies |
| Delay up to 30 days | Multiplier on normal fee | 2 times the normal fee |
| Delay above 30 and up to 60 days | Multiplier on normal fee | 4 times the normal fee |
| Delay above 60 and up to 90 days | Multiplier on normal fee | 6 times the normal fee |
| Delay above 90 and up to 180 days | Multiplier on normal fee | 10 times the normal fee |
| Delay above 180 days | Multiplier on normal fee | 12 times the normal fee |
| Auditor’s certificate, where required | Statutory auditor | Scoped by the auditor |
| Professional fees | CA / CS firm | Scoped after a short discovery call |
The fee slabs are indicative and are amended from time to time, so we confirm the current figures on the portal before payment. Note that the additional fee is the cheap part of a DPT-3 default — the exposure under the rules and section 76A is what makes this worth doing on time.
What happens if a company does not file DPT-3?
- An additional fee on the late filing, on the multiplier slab above
- Penalties under Rule 21 of the deposit rules on the company and on every officer in default, with a continuing daily amount
- Where the company has actually accepted deposits in contravention of Chapter V, the far heavier consequences under section 76A — a substantial minimum penalty on the company linked to the deposit amount, and penalty with possible imprisonment for officers
- A reportable non-compliance in the audit report and the board’s report
- A disclosure that has to be made in diligence, which slows funding and lending
- Reclassification risk — an exempt receipt that breached its conditions is treated as a deposit, retrospectively
The section 76A exposure is not theoretical for companies that drifted. A customer advance not applied or refunded in time, or share application money left pending too long, converts into a deposit accepted without complying with Chapter V — and the penalty for that is measured against the amount involved, not against a filing fee. Separately, default in repaying deposits for a year or more is a disqualification trigger for directors under section 164(2)(b), which leads into DIN reactivation territory.
Does a company with no business activity still file DPT-3?
Yes, if it holds a reportable balance. This is the case we see most often: a company that never launched, funded entirely by a founder’s unsecured loan, with nil revenue and nil operations. The loan is outstanding on 31 March, so the return is due. Inactivity is not an exemption.
A company that has formally obtained dormant status still files what the dormant regime requires — see dormant company — and the deposit return applies to the extent it holds reportable amounts. The cleaner answer for a dead entity is usually to repay the founder’s loan, settle the balance sheet, and either park it as dormant or close it through winding up, rather than carry an annual DPT-3 obligation on a company nobody is running.
What is the DPT-3 checklist for a private limited company?
- 1.Pull the 31 March trial balance and list every credit balance that is not share capital or a trade payable
- 2.Tag each one to the exemption it relies on, or flag it as a possible deposit
- 3.Check director loans have the written declaration that the funds are the director’s own and not borrowed
- 4.Check shareholder loans in a private company against the applicable conditions
- 5.Age customer advances and confirm none has breached its application or refund window
- 6.Age share application money pending allotment and regularise anything past its window
- 7.Compute accrued interest to 31 March on each borrowing
- 8.Decide the correct form purpose and whether an auditor’s certificate is needed
- 9.Reconcile the totals to the financial statements you will file in AOC-4
- 10.File and pay before the operative due date, and confirm the current date against MCA circulars
- 11.Keep the category workings on file — they are what you would produce if queried
How does DPT-3 interact with the rest of the compliance calendar?
DPT-3 falls at the start of the compliance season, ahead of the audit and the annual filings. That ordering is deliberate — the exempted-deposit return does not need audited figures, so it can be done off the draft balance sheet while the audit is still running.
The figures must nonetheless agree with what is eventually filed. A DPT-3 showing a director’s loan the audited balance sheet does not carry, or vice versa, is an inconsistency on the public record. We reconcile DPT-3, the financial statements in AOC-4, and the related-party disclosures as one exercise rather than three.
Companies raising money should also watch the sequence in the other direction: an investor’s money received but not allotted before 31 March is reportable, so allotment timing and authorised capital headroom are worth planning before the year closes rather than after.
Why choose Arjun Filings for DPT-3 filing?
Arjun Filings runs DPT-3 filing as a checklist-first engagement: a qualified CA or CS scopes the work, tells you exactly which documents are needed, and reviews every form before it is signed and submitted. You get a named specialist, a status update at each stage, and a compliance calendar for whatever comes next.
- Specialist support for DPT-3 filing
- Due-date calendar and penalty awareness
- Form review before DSC signing
- Status updates until acknowledgement