Form DPT-3 is the annual return of deposits and outstanding loans (not treated as deposits) that every company — other than a Government company — must file with the Registrar of Companies under Section 73 of the Companies Act 2013 read with Rule 16 of the Companies (Acceptance of Deposits) Rules 2014. It is a sweeping disclosure form designed to bring transparency to all sources of funding raised by an Indian company — capturing both "deposits" within the regulated framework of Sec 73 / Sec 76 and "non-deposit money received" that is exempt under Rule 2(1)(c) (the 18-category exempt list including loans from directors, inter-corporate loans, share application money under Sec 42, customer advances within 365 days, ECBs, secured debentures, banking / FI loans, government grants, and more). The due date is 30 June every year, capturing data as on 31 March of the immediately preceding financial year, and certified by the company's statutory auditor.
Non-filing or mis-filing of DPT-3 has serious consequences. Under Section 76A, accepting deposits in contravention of Sec 73 / 76 attracts a fine of ₹1 crore to ₹10 crore on the company and ₹25 lakh to ₹2 crore (or 7 years imprisonment) on every officer in default — among the harshest penalties in the Companies Act 2013. Even where the money is non-deposit (e.g., director loan or inter-corporate loan), incorrect categorisation, missing the 365-day customer-advance / 60-day share-application-money cut-offs, or breach of Sec 180 borrowing limits can convert "exempt" money into "deemed deposits" — exposing the company to Sec 76A liability. Our DPT-3 filing services deliver end-to-end compliance for Pvt Ltd, Public Ltd, OPC, Section 8, and NBFCs / HFCs (where applicable) — covering classification, exemption mapping, auditor certification, Form DPT-3 filing, director-loan declaration under Rule 2(1)(c)(viii), inter-corporate loan reporting, customer advance ageing, share-application-money reconciliation, ECB Form ECB-2 alignment, NCD / debenture reporting, and Sec 460 condonation for backlog cases.
Annual return of deposits and outstanding loans by every non-government company — by 30 June, capturing position as on 31 March of preceding FY, audited / auditor-certified.
Loan from director with declaration that money is from his / her own funds (not borrowed) — exempt under Rule 2(1)(c)(viii); mandatory reporting in DPT-3.
Loans from holding / subsidiary / associate / fellow-subsidiary companies — exempt under Rule 2(1)(c)(vi) / (vii); Sec 186 compliance + DPT-3.
Advances received against supply of goods / services — exempt only if appropriated within 365 days; beyond 365 days = deemed deposit under Sec 73.
Share application money — exempt only if shares allotted within 60 days under Sec 42; beyond 60 days, money is refundable + deemed deposit if retained.
External Commercial Borrowings (ECB), secured / unsecured non-convertible debentures (NCD), commercial paper (CP) — exempt under Rule 2(1)(c) but reportable.
Pvt Ltd companies cannot accept deposits from public; can accept from members subject to Rule 3 conditions (DRR, deposit insurance, credit rating, advertisement / circular).
Eligible public companies (with NW ≥ ₹100 Cr or turnover ≥ ₹500 Cr + special resolution) can accept public deposits subject to Rule 4 conditions.
Money "not deposit" under Rule 2(1)(c) includes loans from banks / FIs / governments, ECBs, director loans (own-fund), inter-corporate, share application, customer advance, etc.
Customer advance for supply of goods / services is exempt only if adjusted / appropriated within 365 days of receipt; beyond that, treated as deemed deposit.
Share application money must be allotted within 60 days; if not, refunded within 15 days; if still retained, becomes deemed deposit + 12% interest under Sec 42.
Contravention of Sec 73 / 76: company ₹1–10 Cr; every officer in default ₹25 lakh – ₹2 Cr or imprisonment up to 7 years, or both — among the most stringent in the Act.
DPT-3 must be certified by the company's statutory auditor — confirming amounts disclosed reconcile with audited books and that classification under Rule 2(1)(c) is correct.
The one-time return for outstanding receipts from 1 April 2014 to 31 March 2019 (introduced by 2019 amendment) is now historical — every year only the annual DPT-3 applies.
End-to-end annual DPT-3 filing — by 30 June, with auditor certification and full reconciliation against audited financial statements.
Categorisation of every receipt under the 18 exempt heads of Rule 2(1)(c) — director loan, inter-corporate, customer advance, share application, ECB, NCD, etc.
Drafting of director's declaration that loan is from own funds (not borrowed), board approval, loan agreement, repayment schedule, and DPT-3 disclosure.
Sec 186 inter-corporate loan compliance — board / SR approvals, interest at G-Sec yield, charge filings, and DPT-3 reporting.
365-day ageing analysis of customer advances, identification of breach cases, refund / settlement plan, and disclosure under DPT-3.
60-day Sec 42 review of pending share application money, PAS-3 allotment, refund where needed, and DPT-3 disclosure.
External Commercial Borrowings — Form ECB-2 monthly reporting, RBI compliance, and DPT-3 alignment with FEMA records.
Secured / unsecured NCD, listed / unlisted debenture, debenture trustee compliance, charge filing (CHG-9), and DPT-3 inclusion.
Eligible public company deposit framework — DRR, deposit insurance, credit rating, advertisement / circular, DPT-1, DPT-2, and DPT-3.
Backlog DPT-3 filings, additional fees, condonation of delay under Sec 460, and Sec 76A penalty defence.
Identification of deemed-deposit exposure (365-day breach, 60-day breach, Sec 180 limit breach), remediation roadmap, and disclosure plan.
Coordination with statutory auditor for DPT-3 certification, reconciliation working papers, and audit-trail integration with AOC-4 / MGT-7.
Annual DPT-3 due date is approaching — auditor certification, classification, and Form DPT-3 filing must be completed in time.
Company has outstanding loan from director / relative — declaration of own-funds, agreement, and DPT-3 disclosure required.
Company has received loan from holding / subsidiary / associate — Sec 186 + DPT-3 + charge filings to be reconciled.
Customer advances pending beyond 365 days — risk of being treated as deemed deposit; remediation + DPT-3 disclosure needed.
Share application money pending beyond 60 days — Sec 42 risk; refund / allotment + DPT-3 disclosure required.
Company has outstanding ECB, NCD, debenture, or commercial paper — RBI / debenture trustee + DPT-3 alignment needed.
RoC has issued notice for non-filing of DPT-3 in past years — late filings, condonation, and Sec 76A defence required.
Investor due-diligence or auditor wants reconciliation between DPT-3, AOC-4, and audited books — clean-up before Series-A / IPO.
Map every loan / advance / receipt to one of the 18 Rule 2(1)(c) categories or to Sec 73 / 76 deposit framework.
Reconcile DPT-3 disclosure with audited FS, loan ledger, bank statements, FC-GPR / FC-TRS, and ECB Form ECB-2.
Obtain statutory auditor's certificate confirming categorisation and reconciliation with audited books.
File Form DPT-3 with all annexures by 30 June; SRN download, challan, and acknowledgement.
Update tracker, register of deposits, integrate with AOC-4 / MGT-7 and next-year DPT-3 calendar.
Partner with our DPT-3 filing specialists for annual filing, director-loan compliance, inter-corporate loans, customer-advance ageing, share-application reconciliation, ECB / NCD reporting, and Sec 460 condonation.
Talk to a DPT-3 Filing Expert