INC 22A ACTIVE Filing for Older Companies

INC 22A (ACTIVE) was a one time MCA compliance for companies incorporated on or before thirty one December 2017. We file INC 22A with the ten thousand rupees additional fee for Pvt Ltd entities still marked Active Non Compliant on the MCA portal.

One time compliance under rule 25AFor companies incorporated before Dec 201710,000 rupees additional feeRequired to regain Active status

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What INC 22A ACTIVE Was Designed to Do

The Companies (Incorporation) Amendment Rules 2019 inserted rule 25A and introduced form INC 22A, commonly called the ACTIVE form (Active Company Tagging Identities and Verification). Every company incorporated on or before thirty one December 2017 had to file the form by twenty five April 2019. The purpose was to verify the genuineness of the registered office of older companies and to remove shell companies from the active register. The filing required a geo tagged photograph of the registered office with at least one director inside, along with comprehensive details of directors, auditors and KMP.

The original window has long closed. Companies that filed in time are listed as Active on the MCA register. Companies that did not file were marked Active Non Compliant, a status that blocks any further MCA filing until INC 22A is filed with the ten thousand rupees additional fee. The compliance is now relevant mainly for older Pvt Ltd entities that have only recently been revived or for which the status correction has been pending.

Who Is Still Affected by INC 22A

  • Private limited and public limited companies incorporated on or before thirty one December 2017 that did not file INC 22A by the original twenty five April 2019 deadline
  • Companies with current MCA status of Active Non Compliant
  • Companies that have been revived after being struck off and need to file INC 22A as part of the revival process
  • Older companies under post incorporation due diligence by an acquirer or investor where the compliance trail is being cleaned

Documents and Information Filed in INC 22A

Photograph of the inside of the registered office showing at least one director
Photograph of the outside of the registered office showing the name board
Latitude and longitude of the registered office location
Email ID of the company (verified through OTP)
List of all directors with active DIN status
Details of the statutory auditor and cost auditor where applicable
Details of key managerial personnel (Whole Time Director, CFO, CS)
SRN of latest AOC 4 and MGT 7 filings to confirm compliance

Step by Step INC 22A Filing for Active Non Compliant Companies

  1. Confirm MCA StatusThe current status of the company is checked on the MCA portal. INC 22A applies only if the status reads Active Non Compliant.
  2. Update Pending FilingsAny pending AOC 4, MGT 7 or other annual filings are completed before INC 22A is filed, since INC 22A asks for SRNs of the latest annual filings.
  3. Capture Geo Tagged PhotographsPhotographs of the registered office, inside and outside, with at least one director in frame. Latitude and longitude are captured by the camera metadata or manually marked.
  4. Director and Auditor DetailsThe list of active directors, auditor and KMP is compiled. DIN status is verified for every director.
  5. Form Drafting and DSCINC 22A is drafted with all required attachments. A director and a Practicing Company Secretary affix their Class 3 DSCs.
  6. Filing with 10,000 Rupees Additional FeeThe form is filed on the MCA V3 portal with the ten thousand rupees additional fee. On approval, the company status changes back to Active.

Frequently Asked Questions on INC 22A

Is form INC 22A still applicable in 2026?

INC 22A (ACTIVE) was a one time compliance under rule 25A of the Companies (Incorporation) Rules 2014, applicable to companies incorporated on or before thirty one December 2017. The compliance window has long closed. Companies that filed in time are marked Active on the MCA portal. Companies that did not file were marked Active Non Compliant and require filing of INC 22A with a penalty before they can file any other MCA form.

Why was INC 22A introduced?

INC 22A was introduced in 2019 to verify the genuineness of the registered office of older companies and to flush out shell companies. The form required the company to upload a geo tagged photograph of the registered office with the directors inside, along with proof of the office address.

What is the penalty for filing INC 22A late?

Ten thousand rupees fixed penalty. The penalty does not scale with the period of delay; it is a flat additional fee charged at the time of filing. Until the penalty is paid and INC 22A is filed, the company status remains Active Non Compliant and no other MCA filing can go through.

What documents are required for INC 22A?

A photograph of the inside and outside of the registered office showing at least one director, the latitude and longitude of the office location, the email ID of the company, details of statutory auditor, cost auditor (where applicable) and details of all directors and key managerial personnel.

Can the ROC strike off a company for not filing INC 22A?

Yes. Companies with Active Non Compliant status are at higher risk of ROC initiated strike off under section 248 of the Companies Act 2013. If the company has not filed INC 22A and has also been inactive for two financial years, the ROC can issue a strike off notice.

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