DIR-3 KYC: Annual Director KYC Filing Explained

DIR-3 KYC is the MCA’s identity-verification requirement for individuals holding a Director Identification Number (DIN). For the annual filing round falling in FY 2025-26, DIN holders covered as at 31 March 2025 had to complete KYC by 30 September 2025, with a ₹5,000 fee for delayed compliance. However, the revised framework effective from 31 March 2026 introduces three-yearly KYC, so the old annual deadline should not be carried forward automatically.

Who must complete DIR-3 KYC?

KYC applies to individuals covered by Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014, including many DIN holders who are not currently active company directors.

For the annual compliance round due on 30 September 2025, the relevant population was individuals holding a DIN as at 31 March 2025. Coverage included:

• Directors of active, dormant and otherwise non-operational companies.
• Individuals who had resigned from all directorships but retained their DIN.
• Disqualified directors.
• Designated partners of LLPs holding a DIN or the corresponding identification number covered by MCA’s KYC framework.

The obligation attaches to the individual’s identification number, not separately to each company. A person serving on five boards does not file five KYC forms.

However, “every allotted DIN, whatever its status” is too broad. A DIN formally cancelled or surrendered requires a different assessment from one merely deactivated for non-filing. Check the DIN’s status and any pending compliance before proceeding.

Has the annual DIR-3 KYC deadline changed?

Yes, the revised Rule 12A framework effective from 31 March 2026 moves routine KYC to a three-year cycle, replacing the continuing annual requirement.

This makes the original statement that three-yearly KYC was only “proposed” outdated.

For Indian readers reviewing FY 2025-26 records, distinguish the historical filing round from the revised framework:

Point	Annual round falling in FY 2025-26	Revised framework from 31 March 2026
Routine frequency	Annual	Once in three consecutive financial years
Relevant deadline	30 September 2025 for covered DIN holders as at 31 March 2025	30 June in the applicable filing year
Filing approach	DIR-3 KYC or DIR-3 KYC-Web, depending on eligibility	Revised DIR-3 KYC-Web framework
Changes in particulars	Appropriate KYC or DIN-update process	Separate updating obligations continue
Practical check	Was the September 2025 obligation completed?	What is the next due year under the revised rules?

Do not assume either that everyone must file on 30 September 2026 or that nobody needs to act until a later year. Establish the applicable date from the DIN allotment, previous KYC filings, changed particulars and operative MCA instructions.

AY 2026-27 is an income-tax assessment-year label. It does not determine this Companies Act compliance deadline.

When were DIR-3 KYC and DIR-3 KYC-Web used?

Under the annual framework applicable to the September 2025 round, first-time KYC generally required DIR-3 KYC, while eligible repeat filers could use DIR-3 KYC-Web.

The distinction matters when reviewing historical compliance or resolving a missed filing.

Requirement	DIR-3 KYC under the annual framework	DIR-3 KYC-Web under the annual framework
Typical use	First KYC or updating mobile number/email	Earlier KYC completed, with no relevant changes
Director’s DSC	Required	Not required for the ordinary OTP-based confirmation
Professional certification	Practising CA, CS or CMA	Not required for ordinary web confirmation
Contact verification	Mobile and email OTPs	Mobile and email OTPs
Government fee for timely routine filing	Nil	Nil
Delayed compliance fee	₹5,000	₹5,000, where applicable

A change of residential address is not simply a reason to replace web KYC with DIR-3 KYC. Changes to DIN particulars, including address, generally require Form DIR-6 under Rule 12 of the Companies (Appointment and Qualification of Directors) Rules, 2014.

For submissions after the revised framework takes effect, follow the current portal workflow rather than assuming these historical form distinctions remain unchanged.

What documents and contact details should a DIN holder prepare?

Prepare identity and address evidence that matches MCA records, together with the director’s own accessible mobile number and email address.

The usual checklist includes:

• PAN: Mandatory for Indian nationals; check the name and date of birth against PAN records.
• Aadhaar: Keep it available where relevant to the prescribed identity-verification requirements, but do not describe it as universally mandatory for every DIN holder.
• Passport: Mandatory for foreign nationals, with other passport disclosures or attachments as prescribed.
• Address proof: Suitable evidence of the current residential address.
• Personal mobile number and email: Each must be unique to the individual and capable of receiving OTPs.
• DSC: A valid Class 3 DSC where the applicable filing requires digital signing.
• Earlier records: DIN details, previous acknowledgements and any pending update applications.

Foreign documents may need notarisation, apostille or consular authentication, depending on the country and document involved. Complete any required translation or authentication before starting the filing.

How should DIR-3 KYC be filed on the MCA portal?

Start by checking DIN status and the applicable filing obligation, then use the current MCA V3 service and retain evidence of successful completion.

A practical sequence is:

1. Check DIN master data. Confirm whether the DIN is approved, disqualified, deactivated for KYC non-filing, or affected by another issue.
2. Review filing history. Identify the last successful KYC and whether any earlier obligation remains outstanding.
3. Resolve changed particulars. Use the prescribed update route rather than confirming information known to be incorrect.
4. Access the appropriate V3 service. Do not rely on old instructions telling every filer to download an offline eForm.
5. Verify contact details. Complete the required mobile and email OTP process.
6. Attach and authenticate documents. Apply the DSC and professional certification wherever required.
7. Submit and check status. Retain the SRN, acknowledgement, payment receipt and final filing status.

An SRN is a tracking reference. Its generation alone should not be treated as proof that all processing and DIN reactivation are complete.

What does delayed DIR-3 KYC actually cost?

Delayed compliance can attract a ₹5,000 government fee for restoring a DIN deactivated for KYC non-filing, with separate consequences if company filings are also delayed.

A deactivated DIN can prevent acceptance of filings requiring that person’s valid DIN or digital authentication. However, it is inaccurate to say that every company filing necessarily stops. Another eligible, authorised signatory may be available.

Worked example: two companies and a missed deadline

Assume Suresh missed the 30 September 2025 KYC deadline and was the intended signatory for two companies’ AOC-4 filings.

Both companies held their AGMs on 30 September 2025. Their ordinary AOC-4 deadline was 30 October 2025 under Sec. 137 Companies Act, 2013. Assume no extension applied, no alternative signatory was arranged, and both forms were filed on 10 November 2025 after his DIN was restored.

Cost item	Calculation	Amount
Delayed KYC fee	One DIN	₹5,000
Company A’s AOC-4 additional fee	11 days × ₹100	₹1,100
Company B’s AOC-4 additional fee	11 days × ₹100	₹1,100
Total additional government outlay		₹7,200

Normal AOC-4 filing fees and professional charges are excluded. Any separately applicable statutory penalty is also excluded.

The ₹5,000 KYC fee is per DIN, not per company. Completing KYC does not remove an independent disqualification under Sec. 164 Companies Act, 2013.

How SP & SC helps

SP & SC reviews the DIN record, identifies outstanding KYC and update requirements, and coordinates these with company filing deadlines.

Our Bengaluru team helps distinguish KYC deactivation from disqualification, corrects documentation issues and checks whether an alternative authorised signatory can prevent avoidable delays.

We also coordinate mandatory annual filings, including AOC-4, MGT-7 or MGT-7A, and ADT-1 where applicable. Where board changes are genuinely needed, see our director replacement support.

Our fees are a fixed quote after reviewing the case, confirmed before work starts. Government fees are identified separately. Contact SP & SC or WhatsApp +91 90356 74566.

Frequently asked questions

The answers below distinguish the September 2025 annual obligation from the revised KYC framework.

Is 30 September still the deadline every year?

No. It applied to the relevant annual round in 2025. The revised framework effective from 31 March 2026 uses three-yearly KYC with a 30 June deadline in the applicable year.

Is timely DIR-3 KYC free?

Timely routine KYC carries no government filing fee. Delayed compliance attracts ₹5,000 where applicable; professional assistance and certain update filings may involve separate charges.

Can two directors share one mobile number or email?

No. Each director should use their own unique personal mobile number and email address for verification.

Must a disqualified director complete KYC?

Yes. Disqualification does not itself remove the KYC obligation, and completing KYC does not cure the disqualification.

Does resigning from every company end the KYC requirement?

No. Resignation alone does not cancel the DIN. Check continuing KYC obligations unless the DIN has been validly surrendered or cancelled.