What is Form INC-22A ACTIVE?

Form INC-22A, also called the Active Company Tagging Identification and Verification (ACTIVE) form, was notified by MCA under Rule 25A of the Companies (Incorporation) Rules, 2014 as inserted by the Companies (Incorporation) Amendment Rules 2019. The form requires every company incorporated on or before 31 December 2017 to file particulars of its registered office, directors, key managerial personnel, and statutory auditor with the ROC. The filing certifies that the company is operationally active and that the registered office details are verifiable. The form requires geo-tagged photographs of the registered office and director KYC details.

What is the late filing fee for INC-22A?

Under Rule 25A(3) read with Companies (Registration Offices and Fees) Rules, 2014, the late fee for Form INC-22A is ₹10,000 if filed after the original due date. The fee is flat and not calculated on time-elapsed basis, unlike many other ROC forms. The original due date for INC-22A was 25 April 2019, extended to 15 June 2019. Companies that missed the deadline must file with the ₹10,000 late fee, and the ACTIVE-non-compliant tag is removed only after the filing is accepted.

What documents and photographs are required for INC-22A?

INC-22A requires: (a) latitude and longitude geo-tags of the registered office, (b) external photograph of the registered office building showing the company name board, (c) internal photograph showing at least one director or KMP at the registered office, (d) DIN of all directors with active status verified, (e) DSC of any one director, (f) auditor SRN of the appointment filing, (g) details of the latest financial year filings (Form AOC-4 and MGT-7), (h) details of the cost auditor (if applicable), and (i) details of the company secretary (if applicable). The photographs must be recent (within 30 days of filing) and must establish that the company is operationally active at the declared registered office.

What is the ACTIVE-non-compliant tag?

Under Rule 25A(2), if a company fails to file INC-22A, the ROC marks the company as 'ACTIVE-non-compliant' on the MCA master data. The non-compliant status triggers several adverse consequences: (a) the ROC will not accept e-Form SH-7 (change in share capital), e-Form INC-22 (change of registered office), e-Form INC-28 (amalgamation/demerger), e-Form DIR-12 (director appointment or change), or e-Form PAS-3 (return of allotment) from a non-compliant company until INC-22A is filed; (b) the company may be marked as a dormant or potentially struck-off entity for follow-up by the ROC under Section 248 of the Companies Act 2013.

Does INC-22A apply to LLPs and OPCs?

Form INC-22A applies to companies incorporated under the Companies Act 2013, including private limited companies, public limited companies, OPCs, and Section 8 companies. It does not apply to LLPs (which are governed by the LLP Act 2008 with separate compliance forms). For OPCs, the requirement still applies but the documentation can be lighter given the single shareholder. For Section 8 companies, the requirement also applies, and the photograph of the registered office must clearly show the charitable or non-profit nature of operations.

What is the link between INC-22A and the dormant company status under Section 455?

Section 455 of the Companies Act 2013 allows the ROC to declare a company as dormant if it has no significant accounting transactions during the preceding two financial years or has not filed its financial statements. A non-compliant INC-22A is a circumstantial indicator of dormant status. The ROC may invoke Section 248 strike-off proceedings against a company that has failed to file INC-22A combined with delayed AOC-4 and MGT-7 filings. The strike-off can be reversed via a National Company Law Tribunal (NCLT) application under Section 252, but the process takes 6 to 12 months and costs ₹2 to ₹5 lakh in professional fees.

ROC Form INC-22A ACTIVE: the 2026 refresher on active company tagging and the dormant-tag risk

The form that became a recurring compliance touchpoint

When the Ministry of Corporate Affairs notified Form INC-22A under the Companies (Incorporation) Amendment Rules 2019, the stated purpose was a one-time exercise: verify the registered office and operating status of every company incorporated on or before 31 December 2017. The original deadline was 25 April 2019, extended to 15 June 2019. The expectation was that the form would settle into the compliance archive after the one-time exercise.

That is not how it has played out. Seven years on, INC-22A remains a recurring compliance touchpoint for three reasons. First, a significant cohort of companies missed the original deadline and continue to operate with the ACTIVE-non-compliant tag, generating cascading filing rejections. Second, the ROC has tightened the enforcement of Section 248 strike-off proceedings against ACTIVE-non-compliant companies, with regional ROCs running periodic clean-up drives. Third, every change in registered office, director, or share capital triggers the INC-22A check at the back end, surfacing the non-compliant status when the company tries to file the next form.

By May 2026, KAMRIT's ROC desk continues to file 50 to 80 INC-22A late filings every month, including reactivation of struck-off companies. This post walks through the form, the ₹10,000 late fee, the photograph and verification requirements, the ACTIVE-non-compliant tag consequences, and the dormant-company cascade.

The legislative and procedural framework

The basis for Form INC-22A is Rule 25A of the Companies (Incorporation) Rules, 2014, inserted by Notification GSR 95(E) dated 21 February 2019. Rule 25A is read with Section 12 of the Companies Act 2013 (registered office of company) and Section 248 (power of registrar to remove name).

The form applies to every company incorporated on or before 31 December 2017, with limited exceptions for companies that have been struck off or are under liquidation. The exceptions specifically listed in Rule 25A(1) are:

Companies which have been struck off
Companies under the process of strike off
Companies under liquidation
Companies amalgamated or merged with effect from a date prior to the filing date
Companies dissolved

For all other companies, the filing is mandatory, and the failure to file within the original due date (15 June 2019) attracts the ₹10,000 late fee with no further escalation.

The information and documentation required

The form INC-22A is filed online on the MCA21 portal. The information requirement spans four broad categories.

Category 1: Registered office. Latitude and longitude geo-tags. External photograph of the registered office building clearly showing the name plate or signboard of the company. Internal photograph of the registered office showing the working environment with at least one director or KMP visible. Both photographs must be recent (within 30 days of filing) and must be uploaded as JPEG/PNG with EXIF metadata preserved.

Category 2: Directors and KMP. DIN (Director Identification Number) of every director, with the DIN status verified as active. Where any director's DIN is deactivated due to non-filing of DIR-3 KYC, the INC-22A cannot be submitted until the DIR-3 KYC is regularised. Particulars of the Company Secretary (if applicable, mandatory for companies with paid-up capital above ₹10 crore).

Category 3: Auditor. Service Request Number (SRN) of the latest auditor appointment filing (Form ADT-1). The auditor must be a chartered accountant in practice with a valid certificate of practice. For companies above ₹250 crore turnover or ₹50 crore paid-up capital, cost auditor details under Form CRA-2 are also required.

Category 4: Financial filings. SRN of the latest Form AOC-4 (financial statements) and MGT-7 (annual return). Companies that have not filed AOC-4 and MGT-7 cannot file INC-22A, the prerequisite annual filings must be regularised first.

The form requires DSC of any one director and certification by a practising professional (CA, CS, or CMA).

The ACTIVE-non-compliant tag and its cascading consequences

Under Rule 25A(2), if a company fails to file INC-22A, the ROC marks the company as 'ACTIVE-non-compliant' in the MCA master data. The status is visible on the public-facing MCA portal and to all internal ROC systems.

The cascading consequences are as follows.

Consequence 1: Form rejection. The ROC will not accept the following forms from an ACTIVE-non-compliant company:

Form SH-7 (notice to ROC of change in share capital)
Form INC-22 (notice of change of registered office)
Form INC-28 (notice of order of court/tribunal on amalgamation, demerger, etc.)
Form DIR-12 (appointment or change of directors)
Form PAS-3 (return of allotment)

This means the company cannot raise capital, change registered office, appoint or remove directors, or amalgamate while ACTIVE-non-compliant. The compliance burden becomes a structural lock.

Consequence 2: Section 248 strike-off exposure. Section 248 of the Companies Act 2013 empowers the ROC to remove the name of a company from the Register of Companies if there is reasonable cause to believe that the company is not carrying on any business or operations. Non-filing of INC-22A combined with delayed AOC-4 and MGT-7 is a circumstantial indicator that the ROC uses to initiate strike-off proceedings. The ROC issues a public notice under Form STK-5 for 30 days, and unless the company responds with evidence of active operations, the company name is removed from the register.

Consequence 3: Banking and lending impact. A company with an ACTIVE-non-compliant status faces challenges in opening new bank accounts (KYC verification flags the MCA status), securing fresh credit facilities (lender due diligence checks MCA records), and signing new contracts with large counterparties (vendor due diligence flags the status).

Consequence 4: Reactivation cost. Once struck off under Section 248, restoration requires a National Company Law Tribunal application under Section 252. The NCLT application costs ₹2 to ₹5 lakh in legal and professional fees, takes 6 to 12 months, and requires demonstration of active operations through bank statements, invoices, GST filings, and director affidavits.

The compliance reset workflow

For a company in May 2026 that has not filed INC-22A, the reset workflow is as follows.

Step 1: MCA master data check. Log in to mca.gov.in and check the company master data for the ACTIVE status. If marked as ACTIVE-non-compliant, the filing is pending.

Step 2: Prerequisite compliance. Confirm that all directors have valid and active DIN (file DIR-3 KYC where pending), that the latest Form AOC-4 and MGT-7 have been filed (file the pending year filings with late fees first), and that the auditor appointment is registered through Form ADT-1.

Step 3: Photograph collection. Take recent (within 30 days) photographs of the registered office: an external view clearly showing the company name board, and an internal view showing at least one director or KMP at work. Preserve EXIF metadata (most smartphones do this by default). Capture the geo-coordinates of the registered office address.

Step 4: Information compilation. Compile the DIN of all directors, the auditor appointment SRN, the AOC-4 and MGT-7 SRNs, the cost auditor and CS particulars (if applicable), and the latest paid-up capital figure.

Step 5: Form filling and DSC certification. Fill the INC-22A form on the MCA portal. Attach the photographs. Pay the ₹10,000 late fee through online payment. Get the form certified by a practising CA/CS/CMA. Affix DSC of one director.

Step 6: Submission and acknowledgment. Submit the form. The MCA21 system generates a Service Request Number (SRN). The form is processed by the ROC within 7 to 21 working days. On acceptance, the ACTIVE status is updated from "non-compliant" to "compliant" in the master data.

Step 7: Post-acceptance verification. Verify the master data update on the MCA portal. Retain the form acknowledgment in the company compliance file for 8 years.

Dormant company status under Section 455

Section 455 of the Companies Act 2013 allows a company to obtain status of a "dormant company" voluntarily by filing Form MSC-1 with the ROC. A dormant company is defined as one which has no significant accounting transactions during the immediately preceding two financial years. The dormant status allows reduced compliance (no AGM, no annual return, no audit subject to conditions) but preserves the corporate shell.

The link with INC-22A is indirect but operative. The ROC infers potential dormant status when:

INC-22A is non-compliant
AOC-4 has not been filed for 2 or more years
MGT-7 has not been filed for 2 or more years
Statutory auditor has resigned or been removed without replacement

A combination of these triggers can lead the ROC to initiate Section 248 strike-off proceedings against the company. Alternatively, the company can pre-empt the strike-off by filing Form MSC-1 to voluntarily become a dormant company under Section 455, preserving the corporate shell while reducing compliance.

The action plan for May 2026

Master data check. Confirm the ACTIVE status on the MCA portal for every company in the group.
Prerequisite cleanup. File pending DIR-3 KYC, AOC-4, MGT-7 with applicable late fees.
Photograph and geo-tag. Take recent photographs and capture geo-coordinates.
File INC-22A. Pay the ₹10,000 late fee, get the form certified, submit.
Monitor. Track the SRN acceptance status on the MCA portal.
Future incorporation. For companies incorporated after 31 December 2017, INC-22A does not apply, but registered office verification remains under Section 12.
Post-strike-off recovery. For struck-off companies, file Section 252 NCLT application within the 20-year window from strike-off.

Talk to KAMRIT

KAMRIT's MCA compliance desk handles INC-22A filings for over 200 companies every quarter, including end-to-end coordination of photograph collection, geo-tagging, prerequisite DIR-3 KYC and annual filing cleanup, and the SRN tracking. Our fixed-fee engagement covers the ₹10,000 statutory late fee plus our professional fee of ₹5,000 for a single-company filing, with bulk discounts for group restructurings. For struck-off companies requiring NCLT Section 252 restoration, we have a dedicated litigation team that has secured restoration orders for over 60 companies across NCLT Delhi, Mumbai, and Chennai benches. Reach out at kamrit.in to schedule a 30-minute MCA compliance review.

References

Companies Act, 2013, Section 12, Section 248, Section 252, Section 455.
Companies (Incorporation) Rules, 2014, Rule 25A (inserted by Companies (Incorporation) Amendment Rules 2019).
MCA Notification GSR 95(E) dated 21 February 2019.
Companies (Registration Offices and Fees) Rules, 2014.
Form INC-22A, Form INC-22, Form DIR-12, Form PAS-3, Form SH-7, Form ADT-1, Form AOC-4, Form MGT-7.
Section 252 of the Companies Act 2013 (Tribunal restoration).