Loans in Your Books but No DPT-3 Filed? You’re Sitting on a Compliance Time-Bomb

September 24, 2025

Akash Roy

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When it comes to corporate compliance in India, some mistakes look small on the surface but can snowball into serious penalties, credibility loss, and even personal liability for directors. One of the most underestimated among them is the mismatch between loans in your books of accounts and your MCA filings—especially DPT-3.

If your financials reflect loans but your MCA records don’t, you’re already on thin ice. With MCA’s new V3 compliance system actively auto-matching financial statements and filings, this mismatch isn’t just a red flag—it’s a flashing siren waiting to attract attention.

In this blog, we’ll break down:

  • What DPT-3 is and why it matters
  • The risks of skipping or mismatching filings
  • Real consequences for companies and directors
  • Why this is not just about compliance, but also about credibility
  • How to fix this before it becomes a nightmare

Loans in Your Books but No DPT-3 Filed? You’re Sitting on a Compliance Time-Bomb

What is DPT-3?

Form DPT-3 is the return of deposits that companies must file with the Ministry of Corporate Affairs (MCA). It covers:

  • Deposits accepted by the company
  • Particulars of transactions that are not considered deposits (such as certain loans)

Simply put, DPT-3 is MCA’s way of keeping track of your company’s borrowings and liabilities. Whether it’s a loan from a director, inter-corporate loan, or any money received by the company that doesn’t qualify as a deposit, it has to be disclosed through DPT-3.

The Scary Reality: Books vs. MCA

Here’s where the problem begins.
Your books of accounts reflect loans.
But your MCA filings don’t.

This gap instantly signals to regulators that either your books are unreliable or your filings are incomplete. Both are dangerous in the compliance world.

With MCA’s upgraded V3 portal, the system can automatically reconcile your financial statements with your statutory filings. What may have gone unnoticed in the past is now instantly detectable.

What Happens if You Miss DPT-3?

The penalties and consequences aren’t theoretical—they’re very real, and they escalate quickly.

  • Heavy Monetary Penalty
  • ₹5,000 fixed penalty upfront
  • Plus ₹500 per day until compliance is done
  • Even a few months of delay can snowball into lakhs in fines

Personal Liability for Directors

Non-compliance with DPT-3 isn’t just the company’s problem.

Directors can be held personally liable for the failure, exposing them to legal and financial consequences.

Regulatory Scrutiny

An MCA notice is not where you want to be.

Once scrutiny begins, regulators can dig deeper into your records, exposing other weak spots in compliance.

In short: it’s not just a filing issue—it’s a governance issue.

The Bigger Pain: Credibility & Funding

Even if you somehow avoid immediate penalties, the mismatch creates long-term credibility issues.

Investors don’t just review your books—they check MCA filings before due diligence.

Banks and financial institutions cross-verify MCA records when evaluating loan applications.

Auditors highlight non-compliance in their reports.

So if your books show loans but your MCA record doesn’t, the first impression you create is:

🚫 Poor governance

🚫 Weak compliance culture

🚫 High risk for funding or partnerships

For startups, SMEs, and growth-stage businesses, this can be a deal-breaker.

Why the Risk is Higher Now?

In the old MCA system, a mismatch could remain under the radar for years unless someone actively scrutinized your filings.

Not anymore.

With the MCA V3 portal, compliance is being re-engineered with automation and AI-driven checks. The system can auto-match financial statements with annual returns and forms like DPT-3.

That means:

If you think you’re safe, you’re not.
Every passing day increases your penalties and risk.
Notices and inspections are only a matter of time.

How Pitchers Global Helps?

At Pitchers Global, we’ve seen companies lose funding opportunities and directors dragged into avoidable compliance disputes—just because of a missed DPT-3.

Our DPT-3 Compliance Package includes:

  • Gap Analysis: Identifying mismatches between your books and MCA records
  • Corrective Filings: Filing overdue DPT-3 returns and clearing penalties
  • Compliance Monitoring: Ongoing support to ensure you never miss a filing again

We don’t just fix the problem—we build a compliance shield around your business, so you stay safe, credible, and funding-ready.

👉 Don’t wait for an MCA notice.
👉 Don’t wait for penalties to pile up.
👉 Don’t risk your next funding round.Take control today.
Pitchers Global can help you fix this—before it blows up.
📩 Contact us now to safeguard your compliance.

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