DPT-3 by 30 June: Does Your Startup's Loan or Convertible Note Count?
DPT-3 is the annual MCA return of deposits and outstanding loans, due 30 June. Many startups don't realise their director loans, inter-company loans, and convertible notes need to be reported. Here's what counts.
DPT-3 is an annual MCA return reporting a company's deposits and outstanding loans not treated as deposits, as of 31 March, due by 30 June. Most startups assume it doesn't apply to them because they haven't taken "deposits" — but DPT-3 also captures director loans, inter-company loans, and amounts received against convertible instruments, which many funded startups have. If you have any borrowing on the books at 31 March, check this.
What DPT-3 actually reports
DPT-3 isn't only about public deposits (which most startups don't take). It reports the company's outstanding receipts of money or loans as of 31 March — split between amounts that are "deposits" and amounts that are exempt from being treated as deposits but still must be reported. That second category is where startups get caught.
What counts — the items startups miss
Commonly-reportable amounts for a funded startup include:
- Loans from directors (often given in the early days to fund operations)
- Inter-corporate loans from a holding company or group entity
- Amounts received against convertible notes / CCDs pending conversion
- Other outstanding loans not classified as deposits
The point: even a startup that has never taken a single public deposit usually has something reportable, because director and group loans are normal. Assuming "we have no deposits, so DPT-3 doesn't apply" is the typical mistake.
The deadline
- As-of date: 31 March
- Due date: 30 June
- Frequency: annual
It sits alongside the other annual MCA filings — see the ROC annual calendar.
Why bother getting it right
DPT-3 is a low-drama filing that becomes a diligence and penalty issue when skipped: late or missed filing attracts additional fees, and an investor's lawyer checking your MCA filings will notice a gap. It's cheap to file and annoying to explain — exactly the kind of item a clean startup just files on time.
Track the annual filings you'd otherwise forget
DPT-3 has no transaction trigger — it just comes around every June — which is why it's forgotten. ComplianceStack includes it in your applicable annual calendar and reminds you ahead of 30 June, with the filed acknowledgement stored as evidence. Get your free compliance health check.
FAQs
- Who needs to file DPT-3?
- Companies with any outstanding loans or receipts of money as of 31 March — including director loans, inter-company loans, and amounts against convertible instruments — not just companies that took public deposits.
- When is DPT-3 due?
- By 30 June each year, reporting the position as of 31 March.
- Does a convertible note count for DPT-3?
- Amounts received against convertible instruments pending conversion are generally reportable. Confirm the treatment of your specific instrument with your CS.
- We've never taken deposits — do we still file?
- Very likely yes, if you have any director or group loans outstanding. The "no deposits" assumption is the common mistake.
This article is general information, not tax, legal or accounting advice. Statutory timelines and thresholds change by notification — confirm applicability and interpretation with your CA, CS, or lawyer before acting.
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