DIR-3 KYC deadlines in practice: last October's fee-free extension, and what the triennial cycle means now

If a client forwards you an MCA circular about DIR-3 KYC this season, check its date before you act on it. General Circular No. 05/2025, dated 15 October 2025, genuinely extended fee-free DIR-3 KYC filing — to 31 October 2025. That window has closed, the regime it belonged to has since been replaced, and the practical question for firms today is a different one: where does each director sit in the new three-year cycle, and what has to happen within 30 days when their details change?

The October 2025 extension — recent past, accurately stated

General Circular No. 05/2025 (F. No. 8/4/2018_CL-I(P)), issued by the Ministry of Corporate Affairs on 15 October 2025 and continuing General Circular No. 04/2025 dated 29 September 2025, decided to allow filing of e-form DIR-3-KYC and web-form DIR-3-KYC-WEB without filing fee up to 31 October 2025.

Three things about it matter for how you treat it now:

• It was a fee extension, not a change to the underlying obligation — for a fortnight and a half, the filing could be made without the filing fee.
• It named both routes that then existed: the e-form DIR-3-KYC and the web-form DIR-3-KYC-WEB.
• It expired on 31 October 2025. It is not current advice, it cannot be filed under today, and any summary that presents it as a live deadline is a year out of date.

Its real value now is as a marker of how the old regime ended: an annual obligation, a September season, and a late-October fee-free mop-up for the directors who had missed it.

What replaced it: the triennial cycle

On 31 December 2025, the MCA notified G.S.R. 943(E) — the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025 — in force from 31 March 2026. The substituted Rule 12A changes the deadline structure in two moves:

• Triennial filing. Every individual holding a DIN as on 31 March of a financial year files the KYC intimation in Form No. DIR-3-KYC-Web on or before 30 June of the immediately following every third consecutive financial year. Count from the anchor: three consecutive financial years, filing due by 30 June of the third.
• Thirty-day change reporting. In any year, cycle or not, a change in a director's personal mobile number, email address or residential address must be submitted through the same web form within 30 days of the change, with the fee provided under the Companies (Registration Offices and Fees) Rules, 2014.

The two routes the 2025 circular named have also converged: Rule 11 now refers only to Form No. DIR-3-KYC-Web, and the Annexure carries a single substituted form covering KYC compliance, DIN reactivation and detail updates.

The timeline, on one page

What this means in practice

The annual firm-wide deadline is gone; a per-director derived date has replaced it. Two directors of the same company can fall due in different years. A roster-level calendar that says "DIR-3 KYC — June" without naming whose June will miss people quietly, three years apart.

The risk has moved from the deadline to the data. The web form verifies the director's mobile number and email address by OTP. A director who changed numbers in 2027 and told nobody is not a filing problem in the abstract — they are a failed OTP in the last week of their June. The 30-day change-reporting duty exists precisely to keep that from happening, and firms should treat every client intimation about a new number, a new email or a house move as a 30-day filing trigger.

Old circulars need handling, not forwarding. Clients will keep finding the October 2025 extension — it is recent, official and clearly worded. The accurate answer is the timeline above: real circular, closed window, new regime. Sending it on without the dates is how a client files late while believing they were early.

What firms should do

1. Place every director in a cohort now: the financial year their position anchors to, and the 30 June that ends their third consecutive year.
2. Send clients the new standing instruction: report a changed mobile number, email address or residential address immediately — the firm's 30-day clock runs from their change, not from the firm's discovery of it.
3. Retire the old season artefacts: checklists and reminder templates that cite a single annual DIR-3 KYC date, or the October 2025 fee-free window, should be updated to the triennial position before they mislead someone.

FAQ

Can DIR-3 KYC still be filed without a fee under General Circular 05/2025?

No. That circular allowed filing of e-form DIR-3-KYC and web-form DIR-3-KYC-WEB without filing fee up to 31 October 2025. The date has passed; the circular is a record of a closed window, not a live concession.

What is the DIR-3 KYC deadline now?

Under Rule 12A as substituted by GSR 943(E), a DIN holder files Form DIR-3-KYC-Web on or before 30 June of every third consecutive financial year, counting from their position as on 31 March of a financial year. Separately, changes to mobile number, email address or residential address must be reported within 30 days of the change.

A director's KYC was last filed in the old annual regime. How do we place them?

Anchor the count to their position as on 31 March of a financial year and count three consecutive financial years forward — the filing falls due by 30 June of the third. Work it per director from their own filing history rather than assuming the whole roster shares one date.

Does the triennial rule mean contact details can wait three years too?

No — the opposite. Rule 12A(2) requires a change in personal mobile number, email address or residential address to be submitted through Form DIR-3-KYC-Web within 30 days of the change, with the prescribed fee. The three-year cycle covers the periodic intimation only.

Metiq places every director on a firm's roster into their triennial cohort and recomputes the 30 June that applies to them — and flags the 30-day change reports in between, so neither deadline depends on a forwarded circular.

General information only — not professional advice.