DPT-3 Compliance: Provisions, Applicability, Purpose & Due Date

Overview

Form DPT-3, introduced through the Companies (Acceptance of Deposits) Amendment Rules, 2019

and governed under the Companies Act, 2013, is an annual filing requirement applicable to most

companies in India. The form captures information about loans or monies received by a

company that do not qualify as “deposits” under the law. This includes inter-company loans,

funds from directors, or advances beyond permissible timelines.

Due Date: June 30 every year

Reporting Date: Position of outstanding as on March 31

Objectives of Filing DPT-3

• Comprehensive Liability Reporting: Disclosure of all financial liabilities, including exempted borrowings and non-deposit receipts.

• Avoidance of Misclassification: Preventing misuse of regulatory gaps by wrongly labeling deposits.

• Regulatory Oversight: Aids MCA in monitoring borrowing practices and ensuring statutory compliance.

• Stakeholder Transparency: Assures lenders and investors of the company’s financial integrity.

• Policy & Analytics: Supports government in financial planning and sectoral studies through aggregated data.

Legal Framework

• Introduced by: Notification G.S.R. 42(E), dated 22nd January 2019

• Relevant Rule: Rule 16A(3) under the Companies (Acceptance of Deposits) Rules, 2014

• Mandate: All companies (except exempted ones) must file DPT-3 annually, based on audited figures as of March 31.

Who Needs to File?

Applicable To:

• Private Companies

• Public Companies

• One Person Companies

• Small Companies

• Listed & Unlisted Companies

Exempt Entities:

• Banking Companies

• NBFCs (registered with RBI)

• Housing Finance Companies

• Government Companies

Note: Even if no deposits are accepted, companies with any kind of loan or advance must file DPT-3.

Filing Categories in DPT-3 (Remote Buttons)

DPT-3 form has 4 options to choose from based on the nature of transactions:

1. Return of Deposit: For companies with actual deposits (non-exempt).

2. Particulars of Non-Deposit Transactions: Mostly applicable to private companies with exempted borrowings.

3. Both Deposits and Non-Deposits: Companies with a mix of both.

4. One-Time Return: For reporting exempted amounts received between 01.04.2014 and

31.03.2019.📅 Filing Timelines

• Annual Return: File by June 30 for data as of March 31.

• One-Time Return: Applicable to transactions up to 31.03.2019 (now past).

💡 Common Inclusions & Exclusions

Included:

• Loan from Directors (with declaration)

• Inter-corporate Loans

• Loans from Banks, NBFCs, Govt.

• Advances beyond 365 days

Excluded:

• Share application money (within 60 days)

• Advances settled within 365 days

• Remuneration payable

• Debtors/Creditors

✅ Auditor Certificate

Required only when:

• Return includes Deposits (not just exempted)

• Using Remote Button 1 or 3

Compliance Essentials

Who Can a Company Accept Loans From?