DIR-3 KYC: nothing is due this 30 September, and the next filing is 2028

Summary

DIR-3 KYC stopped being an annual filing on 31 March 2026: as Rule 12A now reads, a DIN holder files DIR-3 KYC Web once every third financial year, not every September. Nothing is due on 30 September 2026 or at any point in 2027, and the next filing window is April–June 2028.

The situation

Every September a practice pulls its DIN list and starts chasing directors for KYC. This year that chase is for a date that no longer exists. The amendment came into force on 31 March 2026 — nearly six months ago — and September 2026 compliance calendars published by filing portals and aggregators still carry "DIR-3 KYC — 30 September" as a live row. So does any practice tracker built before April. The cost of the mistake is small in rupees and large in credibility: you ask forty directors for an OTP they did not need to give, and the one director whose DIN is genuinely deactivated gets lost in the noise.

The rule

Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014 was amended by G.S.R. 943(E) dated 31 December 2025, in force 31 March 2026. As amended, every individual holding a Director Identification Number as on 31 March of a financial year files KYC intimation in Form DIR-3 KYC Web on or before 30 June following every third consecutive financial year.

Two amounts sit alongside it, from the Companies (Registration Offices and Fees) Amendment Rules, 2026 of 21 April 2026: ₹5,000 for a late filing or to reactivate a deactivated DIN, and ₹500, as one commentary reports, where a filing is made because the director's own particulars changed.

The separate 30-day duty survives the amendment. Where a director's mobile number, e-mail or residential address changes, the updated KYC is filed within 30 days of the change, whatever stage of the three-year cycle the holder is at — and that update does not restart the cycle (reported).

Where people go wrong

This is not a deferral. Years of DIR-3 KYC have trained the profession to read every MCA announcement on this form as an extension of the date. The date was not extended. The frequency was changed, which means there is no 2026 filing to be extended into 2027.

A deactivated DIN is not cured by it. If a director missed an earlier year and his DIN is marked "Deactivated due to non-filing of DIR-3 KYC", the triennial rule does nothing for him. He still files DIR-3 KYC Web with the ₹5,000 fee to get the DIN restored, and until he does he cannot be appointed to a new board.

30 September is still a real date, for other things. The annual general meeting for a financial year ended 31 March falls due on 30 September under section 96 of the Companies Act, 2013, and the tax-audit report for AY 2026-27 is due the same day under section 44AB of the Income-tax Act, 1961 (its successor, section 63 of the Income-tax Act, 2025, first applies to tax year 2026-27, so this season is still a 1961-Act filing in Forms 3CA/3CB/3CD). Deleting the KYC row from your September board is not the same as emptying it. The trust audit report due the same day is a separate decision: Form 10B or Form 10BB: decide it before 30 September 2026.

The first-cycle question is genuinely open. The reproductions describe the April–June 2028 block by reference to holders whose DIN existed on or before 31 March 2025 and who filed for FY 2025-26. How the three-year count runs for a DIN allotted after that is not settled in the material I can read, and I have not seen the Gazette text itself.

What to do

1. Delete the 30 September 2026 KYC row from your client tracker and put 30 June 2028 in its place.
2. Check each client DIN's status on the MCA portal now, while you have the list open — the amendment changed the cadence, not anyone's past default.
3. Where a DIN shows as deactivated, file DIR-3 KYC Web with the ₹5,000 fee and treat the appointment consequences as a separate conversation.
4. Where a director's contact details or address changed this year, file within 30 days of the change and do not wait for a cycle date.
5. Tell the client in writing that nothing is due. They will see "30 September" on ten other calendars and assume you forgot.

The tool

I keep a board of every client against every statutory date because I stopped trusting my own memory for this, and the DIR-3 correction is exactly why: a tracker is only as good as the week it was last re-read against the rules. The version live now carries the triennial row, so no company or LLP client shows a 30 September KYC date, and non-audit ITR-3/ITR-4 clients sit on 31 August rather than 31 July (the Finance Act, 2026 amended Explanation 2 to section 139(1) of the 1961 Act — section 263 of the Income-tax Act, 2025). You add clients, tick their registrations, and get the GST, TDS, income-tax and ROC dates on one colour-aged screen, a printable client sheet, and a calendar export. It does not file anything, it does not read the MCA portal, and it cannot tell you whether a particular DIN is already deactivated — it gives you the dates, you check the status. Everything stays in your browser.

Open the deadline board

Sources

1. SCC Online, Companies (Registration Offices and Fees) Amendment Rules, 2026 — DIR-3 KYC fee changes (Rule 12A as amended, quoted) — https://www.scconline.com/blog/post/2026/04/24/companies-registration-offices-fees-amendment-rules-2026-dir-3-kyc-fee-changes/
2. CorpLawUpdates, DIR-3 KYC Web 2026 — complete guide (G.S.R. 943(E) dated 31 December 2025; first triennial block April–June 2028) — https://www.corplawupdates.in/updates/dir-3-kyc-web-2026-complete-guide
3. MCA / PIB press release on the amendment, PRID 2210552 — https://www.pib.gov.in/PressReleasePage.aspx?PRID=2210552