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Return of deposits, DPT-3

  • Every company must report, by 30 June, any loans or advances it holds as on 31 March, including those that are not treated as deposits, like director loans or customer advances.
  • Deadline: By 30 June every year, with figures as on 31 March
  • Done in 2 working days after loan ledgers and confirmations
  • Prepared by your Savvy, checked by a CA
  1. Loan and advance ledgers at 31 March
  2. Is the company a Government company
  3. List every loan
  4. SRN and challan
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Answer in brief

Every company must report, by 30 June, any loans or advances it holds as on 31 March, including those that are not treated as deposits, like director loans or customer advances. We sort each item into the right category, file DPT-3 on MCA and get the auditor's certificate only where the law needs it.

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From the official sources

What the law says, and what trips people up

From the official portal's manuals and FAQs, with the source for each point.

The law

  • Companies (Acceptance of Deposits) Rules 2014, Rule 16

    Every company to which the rules apply files a return in Form DPT-3 by 30 June each year with information as on 31 March, audited by the company's auditor; applies to every company other than a Government companySource

  • Companies (Acceptance of Deposits) Amendment Rules 2022, G.S.R. 663(E) dated 29 August 2022

    Revised DPT-3; auditor's declaration is now given in the form; adds movement and ageing of money not treated as depositsSource

  • Rule 16A(3)

    One-time return of outstanding receipts of money or loans for 1 April 2014 to 31 March 2019 (past requirement)Source

  • Rule 2(1)(c)

    List of receipts that are not deposits (e.g. bank loans, inter-corporate loans, director loans, certain advances, share application money pending allotment, start-up convertible notes)Source

  • Rule 21

    Fine up to ₹5,000 for the company and every officer in default, plus up to ₹500 a day for a continuing contraventionSource

  • Government fee

    Normal filing fee by nominal share capital under the Table of Fees, Companies (Registration Offices and Fees) Rules 2014: ₹200 (below ₹1,00,000) to ₹600 (₹1 crore and above). Source: https://ca2013.com/403-fee-for-filing-etc/

  • Late fee or penalty

    Additional fee as a multiple of the normal fee (G.S.R. 12(E), from 1 July 2022, for forms other than Sec 92/137, capital increase and charge forms): up to 30 days 2x; 30 to 60 days 4x; 60 to 90 days 6x; 90 to 180 days 10x; beyond 180 days 12x. Source: https://ca2013.com/wp-content/uploads/2022/01/Companies-Fees-Rules-2022.pdf . Separate fine under Rule 21: up to ₹5,000 plus up to ₹500 a day. Source: https://ca2013.com/rule-21-companies-acceptance-of-deposits-rules-2014/

On the portal

  1. Login to MCA V3 with the business user ID
  2. MCA Services > E-Filing > Company Forms > DPT-3
  3. Enter CIN; choose purpose (return of deposits, or other as applicable)
  4. Enter financial year end, net worth and deposit particulars if any
  5. Fill the table of money not treated as deposits with opening, receipts, repayments, closing and ageing
  6. Attach auditor's certificate (if deposits), list of depositors and trust deed where applicable
  7. Submit for SRN, affix DSC, pay online

What trips people up

  • Director loans from borrowed funds and loans from non-director shareholders reported as exempt

    Treat them as deposits; take the own-funds declaration from directorsSource

  • Form will not upload without auditor DSC even when only exempted items are reported

    Keep the auditor available to sign or check the form's certification sectionSource

  • Receipt taken and repaid within the year, nothing at 31 March: unclear whether to report

    Practitioners suggest reporting the movement; confirm with the formSource

  • Company skips DPT-3 thinking it has 'no deposits' while it holds exempt loans

    Outstanding exempt receipts must still be reportedSource

People ask

Do OPCs and small companies file DPT-3?

Yes, every company including OPC and small companies, except Government companies, banks, RBI-registered NBFCs and HFCs.Source

Is the auditor's certificate always needed?

No. Not needed if only exempted deposits are reported; mandatory if deposits are reported.Source

Can we file before the audit is over?

Yes, DPT-3 can be filed on unaudited figures.Source

Is DPT-3 a one-time return?

There was a one-time return for 2014 to 2019 receipts under Rule 16A(3). The annual DPT-3 under Rule 16 is due every 30 June.Source

IDFD

How we solve it: 4 steps

Every line tracked live.

Step 1 of 4 · What we need from you

Tap each one you already have

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  • Loan and advance ledgers at 31 March
  • Director's own-funds declaration
  • Lender type for each loan
  • Opening, receipts, repayments, closing
  • Ageing of each exempted item
  • Customer advance and share money datesOptional
  • Auditor certificate (if deposits)Optional
  • Trust deed, depositor list, charge SRNsOptional
  • Signing director DSC

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Yearly. Delivered in 2 working days after loan ledgers and confirmations. Due: By 30 June every year, with figures as on 31 March

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