DPT-3 Annual Return on Deposits and Loans for Indian Companies

DPT-3 is the annual return that discloses all money received by a company that is either a deposit (regulated under Section 73 of the Companies Act 2013) or an exempt receipt (excluded from the deposit definition under Rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules 2014). It is filed by every company except government companies, and the disclosure captures the company's outstanding position as on 31 March of the relevant financial year. The form has two purposes: it is the regulatory window into deposit acceptance, and it is the recurring disclosure that ensures the company stays compliant with the deposit rules.

Every company registered under the Companies Act except government companies. So Pvt Ltds, OPCs, Public Ltds (listed and unlisted) all file. Section 8 (not-for-profit) companies also file. Beyond government companies, the following are also exempt under Rule 1(3) of the Companies (Acceptance of Deposits) Rules 2014: banking companies, Non-Banking Financial Companies (NBFCs registered with RBI), and Housing Finance Companies registered with the National Housing Bank. There is no turnover threshold, no minimum capital, and no exemption based on size for any other company.

DPT-3 is due by 30 June every year, capturing the position as on 31 March. So for FY 2025-26 (the snapshot date of 31 March 2026), the filing deadline is 30 June 2026. The 90-day window from 31 March to 30 June is meant for the company to close books, get the audit done, and reconcile balances, but in practice most companies file in the last two weeks.

DPT-3 captures all money received that is either a regulated deposit or an exempt receipt. Most growing companies have a mix of both.

When DPT-3 was first introduced (via the Companies (Acceptance of Deposits) Amendment Rules 2019), every company had to file a one-time return capturing all outstanding deposits and covered receipts as on 31 March 2019, plus annual returns thereafter. That one-time obligation is now done for all companies in existence at that time. New companies (incorporated after the original cut-off) just file the annual return from the year of incorporation onwards. The MCA portal still allows the form to be filed in either mode (one-time or annual), and most filings are now in annual mode.

The single most important DPT-3 distinction is between regulated deposits and exempt receipts. Regulated deposits trigger Section 73 obligations (deposit insurance, escrow, registration with Reserve Bank in some cases). Exempt receipts have to be disclosed in DPT-3 but don't trigger the Section 73 framework.

Two penalties stack on a missed DPT-3.

Strictly under the Companies (Acceptance of Deposits) Rules 2014, a NIL DPT-3 (zero outstanding deposits, zero exempted receipts as on 31 March) is not legally mandatory. The trigger for the form is the existence of deposits or covered receipts to report. However, many practitioners file a precautionary NIL DPT-3 to maintain a clean compliance record, since: (a) the absence of a filing can be interpreted as oversight in due diligence, and (b) the form is cheap and quick to file (Rs 300 in MCA fees, 30 minutes of work). Most companies that have any director loans, share application money pending allotment, or group company advances will have something to report and won't qualify as truly NIL. A common compliance error is treating director loans as personal and skipping disclosure. Director loans are exempt receipts and must be disclosed in DPT-3.