Form DPT-3 — the 30-June return every company misses

Why DPT-3 exists

The Companies (Acceptance of Deposits) Rules 2014 distinguish between "deposits" (regulated, restricted, capped) and "non-deposit money receipts" (exempt categories like loans from directors, inter-corporate borrowings, share application money). DPT-3 was introduced in 2019 to give MCA full visibility into both — companies were structuring routine loans as "exempt" without disclosure, and MCA needed an annual snapshot.

Who files

Every company except a banking company, NBFC and HFC. So: public, private, OPC, Sec 8, dormant — all in scope. Even if you have nothing to report (no loans, no deposits, no advances), most companies still need to file a NIL DPT-3 confirming the position.

The four scenarios

DPT-3 has a "Purpose" dropdown with four options:

1. One-time return for outstanding receipts not considered as deposits (per Rule 16A) — historical filing, mostly relevant for 2019 transition. Skip in routine annual cycles.
2. Return of deposit — only if your company actually accepts deposits under Sec 73 (public deposit) or Sec 76 (eligible companies). Most private companies don't.
3. Return of exempted deposit — money received that is excluded from the deposit definition. Common: loans from directors, inter-corporate loans, share application money pending allotment, advance against capital goods/services from customers, security deposits from employees.
4. Return of both — if you have actual deposits AND exempted receipts.

The most common annual filing: option 3 (return of exempted deposit). Nearly every operating private company has at least a director loan or an unpaid intercompany balance.

What counts as "exempt deposit"

Rule 2(1)(c) of the Deposit Rules lists 19 exempt categories. The ones we see most often:

• Loans from a banking company, financial institution.
• Money received in the course of business: (a) advance from customer for supply of goods / services, (b) advance from buyer in connection with consideration for property under an agreement.
• Money received from directors of the company OR from a relative of a director (subject to a declaration that the loan was not from borrowed funds of the director).
• Money received from another company.
• Money received against issue of commercial paper / other listed debt securities.
• Share application money — pending allotment for up to 60 days from receipt; beyond that it becomes a deposit unless refunded.
• Promoter contribution by way of unsecured loan to comply with stipulation imposed by lending bank / FI.
• Amount received from employees up to 25% of their annual salary as a non-interest bearing security deposit.
• Foreign loans / commercial borrowings.

Filing windows

The auditor certificate

DPT-3 mandates an auditor's certificate. The auditor confirms the figures in the form match the audited financial statements. So your FY 2025-26 audit must be substantially complete before DPT-3 can be filed (or at least the loan / deposit balances reconciled). This is why many companies push DPT-3 to the very last week of June — audit completion runs in parallel.

Penalty for non-filing

Rule 21 of the Deposit Rules read with Sec 76A of the Companies Act:

• Company: minimum ₹1 crore or twice the amount of deposits accepted, whichever is lower, extending to ₹10 Cr.
• Every officer in default: ₹25 lakh to ₹2 crore + 7 years imprisonment.

In practice, MCA prosecutes only egregious cases where actual deposits were accepted without compliance. For belated DPT-3 of exempt-deposit categories, MCA typically permits voluntary filing with ₹100/day late fees subject to maximum 12x the normal fee. Far gentler than Sec 76A penalty, but still avoidable.

Common defaults we see

1. "We don't have deposits, so we don't file." The most common excuse. The form captures exempted receipts. Almost every company has at least one balance in scope.
2. Share application money > 60 days unallotted. Auto-converts to a deposit. Either refund within 60 days or allot. Don't leave it sitting.
3. Director loan without declaration. Without the source-of-funds declaration, the loan flips from exempt to non-exempt deposit. Audit risk every year.
4. Including operating creditors / payables. Trade payables for goods / services in ordinary course are NOT in scope. Don't bloat the DPT-3 with creditors.
5. Forgetting inter-company loan from group company. Inter-corporate loans are exempt deposits and must be disclosed. Receivables from group are out of scope, but loans payable are in.
6. Missing the auditor certificate. DPT-3 with no audit-aligned figures will fail. Coordinate with auditor to lock the loan-ledger reconciliation by end-May.

Step-by-step process

1. April: Pull the trial balance as on 31-March. Identify every loan / deposit / advance balance.
2. Mid-April: Categorise each into "deposit" / "exempt deposit" / "out of scope".
3. Late April: Coordinate with auditor on the reconciliation.
4. May: Collect director / group source-of-funds declarations.
5. 1st week of June: Get auditor certificate.
6. 15-June: Prepare DPT-3 in MCA portal.
7. By 25-June: File. Save SRN.

What if you missed past years

Voluntary belated DPT-3 with ₹100/day late fee per year is permitted under the additional fee regime. We've cleared up to 4 years of backlog DPT-3 for clients with minimal regulatory friction — the key is voluntary disclosure with a covering letter to the jurisdictional ROC. Penalty under Sec 76A is rarely invoked for exempt-deposit-only filings.

Bottom line

DPT-3 is a "thoughtless" annual filing that catches almost every operating company — director loans, group loans, employee security deposits, share application money. Don't assume "we don't take deposits". Reconcile the trial balance as of 31-March, classify each receipt against Rule 2(1)(c), document the director / group declarations, lock the auditor certificate by early June, and file by 30-June. The cost of compliance is one analyst-day. The cost of default is potentially catastrophic if non-exempt deposit acceptance is later discovered.

Related

• DPT-3 scope checker
• ROC annual filing — AOC-4 + MGT-7
• DIR-3 KYC — director KYC every three years
• Form MSME-1 — half-yearly return