What deadlines does a new subsidiary face first?
The first six months are the most time-sensitive. Several clocks start on incorporation and run in parallel, and missing one can hold up others.
| Item | Deadline | Basis |
|---|---|---|
| First board meeting | Within 30 days of incorporation | Companies Act, section 173 |
| First auditor appointed by the board | Within 30 days of registration | Companies Act, section 139 |
| Filing of the auditor’s appointment with the Registrar | Filed after the appointment | Registrar of Companies |
| Allotment of shares (fresh allotment; not the subscriber shares issued at incorporation) | Within 60 days of receipt of funds | FEMA rules |
| FC-GPR | Within 30 days of allotment | RBI FIRMS portal |
| INC-20A, commencement of business | Within 180 days of incorporation | Companies Act, section 10A |
The board must hold the first meeting and appoint the auditor within the same 30 days, so schedule one meeting that covers both. Our guide to bank accounts and capital remittance explains how the capital dates fit together.
What recurs every year?
| Item | Timing | Notes |
|---|---|---|
| FLA return | By 15 July, for the preceding financial year | Filed on RBI’s FLAIR portal, even with no transactions |
| First AGM | Within 9 months of the end of the first financial year | Companies Act, section 96 |
| Later AGMs | Within 6 months of financial year end, and no more than 15 months apart | Companies Act, section 96 |
| Statutory audit and audit report | Completed before the AGM, since the audited financial statements must be laid at the AGM | Companies Act, section 139 |
| Financial statements (AOC-4) | Within 30 days of the AGM | Registrar of Companies |
| Annual return (MGT-7) | Within 60 days of the AGM | Registrar of Companies |
| Board meetings | At least four a year, no more than 120 days apart | Companies Act, section 173 |
| DPT-3 (return of deposits) | By 30 June each year, for the position as at 31 March | Companies (Acceptance of Deposits) Rules |
| MSME-1 (dues to micro and small enterprise suppliers outstanding more than 45 days) | Half-yearly, by 30 April and 31 October | Specified Companies (Furnishing of Information about Payment to Micro and Small Enterprise Suppliers) Order |
Do not assume the lighter small-company forms or board-meeting relaxations are open to a foreign-owned subsidiary. Whether a company held by a foreign parent qualifies is an interpretation point to confirm with a CS or CA. At ProLead, we do not apply small-company exemptions to a subsidiary of a parent.
What recurs less often?
| Item | Timing | Notes |
|---|---|---|
| Director KYC (DIR-3 KYC) | By 30 June, once every three consecutive financial years, from 31 March 2026 | Includes foreign national directors; changes to contact details within 30 days |
Non-filing deactivates the DIN, and reactivation carries a fee. The older annual 30 September deadline has been superseded, although some websites still print it. Under the new rule, DINs allotted in FY 2025-26 first fall due on 30 June 2029.
What tax and payroll dates apply?
Tax, GST, payroll and beneficial-ownership filings have their own dates:
- Income tax return. Due on 31 October, or 30 November where a transfer-pricing report in Form 48 is required. See transfer pricing basics for when Form 48 itself falls due.
- Quarterly TDS returns and deposits. Returns are due by 31 July, 31 October, 31 January and 31 May for the four quarters of the financial year. Tax deducted must be deposited by the 7th of the following month, except for March, which is due by 30 April.
- GST returns, once registered. See our GST guide for the return frequency and due dates.
- Provident fund and ESI contributions. Due by the 15th of the following month. State levies such as professional tax vary by state, so check the due date with your state authority.
- Significant beneficial owner declarations, where they apply. The SBO’s own declaration (Form BEN-1) is due within 90 days of becoming, or ceasing to be, a significant beneficial owner, and the company then files Form BEN-2 within 30 days of receiving it.
What triggers an extra filing?
Some filings depend on events, not the calendar. A share transfer between a resident and a non-resident carries its own FEMA deadline of 60 days, and downstream investment has a 30-day report. A change of director, address or auditor also needs a Registrar filing. See FEMA filings for the FEMA forms.
How should you manage the calendar?
- Set the financial year end and book the AGM date in the first month.
- Put the fixed dates in a shared calendar: 30 days, 180 days, 30 June, 15 July.
- Assign each filing to a named owner, either your finance lead or ProLead’s professionals.
- Review the calendar every quarter, since forms and dates change.
ProLead’s accounting, tax and compliance service keeps this calendar for foreign-owned subsidiaries and coordinates filings with a CS or CA. You can book a free consultation to see how it would work for you.
Note: Rules and forms change often. This page is general information, not legal or tax advice. Check the current position with a practising Chartered Accountant or Company Secretary before you act.
Frequently asked questions
What must a new Indian subsidiary do in its first 30 days?
When is the FLA return due?
How often must directors file KYC now?
When must INC-20A be filed?
Sources
General information only, not legal or tax advice. Rules and forms change, so confirm the current position with a practising Chartered Accountant or Company Secretary before you act. See our disclaimer.