Most compliance problems don’t happen because businesses want to skip the law.
They happen because deadlines overlap, extensions create confusion, and “we’ll do it next week” quietly turns into penalties.
January 2026 is one of those months.
On paper, it looks light—most annual ROC filings for FY 2024–25 were already extended till 31 December 2025. Many directors assume January is safe.
It isn’t.
Between TDS returns for Q3, pending ROC filings, and event-based MCA compliances, January 2026 can quietly become expensive if ignored.
Let’s break it down clearly—no jargon, no scare tactics, just what actually matters.
January 2026 Compliance Snapshot: What’s Due and Why It Matters
January sits right after the year-end rush. That’s exactly why compliance gaps show up now.
Here’s what companies should focus on:
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TDS returns for Q3 (October–December 2025) as per the Income Tax Department’s quarterly TDS framework
👉 https://www.incometax.gov.in/iec/foportal/help/tds-returns -
Any pending ROC annual filings on the MCA portal
👉 https://www.mca.gov.in -
Event-based ROC filings triggered in recent months
-
Monthly or quarterly MCA compliances, if applicable
Missing any of these doesn’t just mean a late fee. It can affect director compliance status, block filings later, and invite notices.
TDS Returns for Q3: Deadline You Can’t Push
TDS Returns for Q3 by January 31, 2026
This is the biggest hard stop for January.
Companies that deduct TDS must file quarterly returns for the period October to December 2025 by 31 January 2026, as notified under Rule 31A of the Income-tax Rules.
Applicable forms include:
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Form 24Q – TDS on salary
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Form 26Q – TDS on domestic payments
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Form 27Q – TDS on payments to non-residents
(Official reference:
https://www.incometax.gov.in/iec/foportal/tds-returns)
Even companies that have properly deducted and paid TDS often slip up here—returns get delayed, mismatches occur, or filings are forgotten entirely.
Real-life example:
A company deducted TDS correctly every month. But the accountant missed filing Form 26Q by the deadline. Result? Late filing fees under Section 234E at ₹200 per day, capped at the TDS amount—plus unnecessary follow-ups from the department.
If you’re tracking January 2026 compliance due dates, this one sits right at the top.
ROC Compliance in January 2026: What Still Needs Attention
Annual ROC Filings: Extensions Are Over
For FY 2024–25, the government had extended deadlines for:
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AOC-4 (financial statements)
-
MGT-7 / MGT-7A (annual return)
The final extended deadline was 31 December 2025, as reflected on the MCA portal
👉 https://www.mca.gov.in/content/mca/global/en/mca/master-data/MDS.html
If these filings are still pending in January 2026, the company is already in default.
At this stage:
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Late fees accumulate daily
-
Director DINs may face deactivation risk
-
The company’s compliance score takes a hit
This is why businesses should file any pending ROC filings immediately, even if they’re already late. Delay only increases cost.
Event-Based ROC Filings: The Silent Risk Area
Unlike annual filings, event-based ROC compliances don’t wait for a fixed month.
They trigger based on actions taken by the company, and timelines are strict under the Companies Act, 2013.
Common examples include:
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Change in directors or KMP
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Allotment or transfer of shares
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Change in registered office
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Increase in authorised capital
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Loan creation or satisfaction
(All these require specific e-forms under MCA
👉 https://www.mca.gov.in/content/mca/global/en/e-forms.html)
Many companies assume these were “handled earlier” but never verify whether the actual MCA forms were filed and approved.
January is a good month to audit this because:
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Late fees for some ROC forms are unlimited
-
Non-filing can block future MCA actions
-
Banks and investors now routinely check ROC records during due diligence
Ignoring these is one of the most common ROC compliance mistakes seen in growing companies.
Why January Compliance Is More Dangerous Than It Looks
January feels calm. That’s the trap.
Here’s why problems surface now:
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Accountants change or take year-end leave
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Compliance is assumed to be “done” after December
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Data mismatches from earlier quarters show up in Form 26AS / AIS
👉 https://www.incometax.gov.in/iec/foportal/ais-taxpayer-information-summary -
MCA and Income Tax systems flag pending defaults automatically
By the time a notice arrives, you’ve lost the chance to fix it cheaply.
That’s why ROC compliance deadlines should be reviewed at the start of January, not the end.
Action Steps for Businesses in January 2026
If you’re running a company, this is what actually helps:
Confirm TDS Q3 filings
Don’t just assume payment equals compliance. Verify returns are filed and acknowledgements are generated on the TRACES / Income Tax portal.
Check ROC filing status
Log in to the MCA portal and confirm whether AOC-4 and MGT-7 are marked “Approved.”
Review the last 6 months of company events
Any director change, share allotment, or address update needs verification.
Clear pending filings immediately
Even late filings are better done now than later.
Document everything
Keep challans, SRNs, and acknowledgements ready. They save time if queries arise.
This simple checklist prevents most January compliance disasters.
Common Compliance Mistakes to Avoid
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Assuming extensions apply forever
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Paying TDS but skipping returns
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Believing the consultant “must have filed it” without proof
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Ignoring small MCA events
-
Waiting for a notice before acting
These mistakes cost far more than timely filing ever would.
Pro Tips from the Ground
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File TDS returns a few days before 31 January to avoid portal load issues
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Don’t club multiple ROC fixes together—some forms block others
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Always reconcile Form 26AS and AIS after filing TDS returns
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Maintain a rolling compliance calendar, not an annual panic list
Small discipline beats big penalties.
Conclusion: January 2026 Is a Checkpoint, Not a Break
January isn’t a slow month for compliance—it’s a checkpoint.
If businesses take the time now to handle TDS returns for Q3 by January 31, 2026, clear pending ROC filings, and review event-based MCA compliances, the rest of the year stays clean.
Ignore it, and penalties quietly pile up.
If you’re unsure where you stand, now is the cheapest time to find out—and fix it.
