MCA21 V2 Decommissioning T-53 Days: The Final 5-Week Sprint to the June 30, 2026 Cutover and the Migration Gaps Practitioners Are Still Hitting
Quick Summary: MCA21 V2 Decommissioning T-53 Days
- Hard cutover date: June 30, 2026. From July 1, 2026 the V2 portal goes read-only and no fresh filings, downloads, or DSC re-registrations will be accepted on V2.
- Status on Friday, May 8, 2026: 53 calendar days remain. Approximately 7.5 weeks of working time after factoring weekends and bank holidays.
- What Post 714 (April 28, 2026) said: 9-week migration checklist, scope of decommissioning, V2 form retirement list. This sequel narrows the lens to the gaps practitioners are still hitting at week 7 and the final 5-week sprint.
- Top three gaps observed in client portfolios: orphan DSCs not re-registered on V3, charge filings (CHG-1, CHG-4, CHG-9) stuck mid-workflow on V2, and historical attachment downloads not yet exported.
- Operational priority: any V2-only filing not concluded by June 26, 2026 carries real risk of re-filing on V3 from scratch with re-uploaded attachments and re-affixed DSCs.
Why this advisory is urgent now
On April 28, 2026 we published a 9-week migration checklist (Post 714: MCA21 V2 Portal Decommissioning June 30, 2026) covering the scope of the decommissioning, the V2 form retirement list, and the high-level migration steps. Friday, May 8, 2026 is week 7 of that countdown. Roughly 53 calendar days separate today from the June 30, 2026 hard cutover and from July 1, 2026 the V2 portal moves to read-only mode. From that day no fresh form upload, no DSC re-registration, no resubmission, and no historical attachment download will go through V2.
This sequel piece is not a rerun of the 9-week checklist. It is a narrow operational read of what practitioners on our calls and in our circles are actually still hitting at week 7 of the countdown. If Post 714 was the strategy memo, this is the week-by-week sprint plan to land the migration cleanly. The intended reader is a Company Secretary, a CS-tracked CA, or an in-house compliance lead who has finished the V3 onboarding but is still carrying a tail of V2-only items.
The 53-day clock: a calendar view of the final sprint
Reading the calendar from Friday May 8, 2026 to Tuesday June 30, 2026, the actual working window is tighter than the 53-day headline suggests.
| Week | Dates | Working days | Recommended sprint focus |
|---|---|---|---|
| Week 7 | May 8 to May 15 | 5 | Inventory: pull a complete list of pending V2 filings, orphan DSCs, and historical attachments to export. |
| Week 8 | May 18 to May 22 | 5 | DSC migration: re-register every active signing DSC on V3 (Director, Authorised Signatory, Practising Professional). Confirm role mapping. |
| Week 9 | May 25 to May 29 | 5 | Charge filings: close out CHG-1 / CHG-4 / CHG-9 mid-workflow items on V2 or restart on V3. Coordinate with banks. |
| Week 10 | June 1 to June 5 | 5 | Annual return prep: complete or queue MGT-7 / MGT-7A / AOC-4 V3 trial drafts for FY 2025-26 (early; see operational note below). |
| Week 11 | June 8 to June 12 | 5 | Historical exports: pull every attachment a client may need post-July 1 (charge documents, board resolutions, MoA/AoA, balance sheets). Save off-portal. |
| Week 12 | June 15 to June 19 | 5 | Resubmissions: clear every “Mark for resubmission” V2 status. After June 26, V2 resubmission is a closing window. |
| Week 13 | June 22 to June 26 | 5 | Last call: any V2 filing not signed and uploaded by close of business June 26 is at risk. Allow buffer for portal load. |
| Week 14 | June 29 to June 30 | 2 | Final smoke test on V3 for every client portfolio. Standby for portal congestion. |
Operational note on annual returns: the FY 2025-26 annual return cycle (MGT-7 / MGT-7A / AOC-4) does not require filing by June 30 in most cases. The 60-day clock from the AGM date is the statutory trigger under Section 92 of the Companies Act 2013. The reason to draft early in week 10 is to surface any V3 form schema mismatch with prior data while V2 is still live for cross-checking historical filings.
The five gaps practitioners are still hitting at week 7
Gap 1: Orphan DSCs that were never re-registered on V3
This is the most common gap in our review of portfolios. Many directors and authorised signatories had their DSC registered only on V2 over the past 5 to 8 years. The V3 portal requires a fresh DSC association under the new identity verification flow. Until that is done, even an active and valid DSC will not let the holder sign a V3 form.
Fix: log into V3 with the holder’s MCA credentials, navigate to Profile, select Associate DSC, and complete the OTP-plus-DSC validation. Allow 10 to 15 minutes per holder. Plan a session to walk every signing director through this step. Do not leave it to the holder; they will defer it.
Gap 2: Charge filings (CHG-1, CHG-4, CHG-9) mid-workflow on V2
Charge filings have a tight 30-day statutory window under Section 77 of the Companies Act 2013 (60 days with additional fee under proviso). Any CHG-1 or CHG-4 sitting in V2 with a “Mark for resubmission” or “Pending payment” status is a potential statutory miss if it crosses June 30 unfinished.
Fix: pull the V2 charge filing register for every active client. For each open item, decide by Friday May 22, 2026 whether to push it through on V2 or restart on V3. Coordinate with the lender’s documentation team because their systems may still reference V2 SRN numbers. The CKYC-charge linkage on V3 is a known friction point; allow extra time.
Gap 3: Historical attachment downloads not yet exported
Practitioners often discover too late that their working files reference attachments held on V2: certified copies of MoA / AoA, board resolutions filed with prior MGT-14 forms, charge instruments filed with old CHG-1, balance sheets and AOC-4 attachments. From July 1, 2026 V2 is read-only; downloads may continue but should not be relied on as the working repository.
Fix: by June 12, 2026, complete a full-portfolio attachment export. For each entity, save a folder containing CIN-named subfolders by year for: MoA / AoA, INC-22 (registered office), DIR-12 history, MGT-14 special resolutions, AOC-4 financials, MGT-7 annual returns, charge documents (CHG-1/4/9). Rolling forward into V3, you want these attachments off-portal under client custody.
Gap 4: SRN cross-references in client correspondence
Letters, NOCs, lender confirmations, and even GST registrations often quote V2 SRN numbers as evidence of MCA filings. After June 30, 2026 the V2 SRN remains a valid record but the lookup is read-only. New filings on V3 generate new SRN formats. Anything pending that could trigger a cross-reference query should be cleared this month.
Fix: instruct articled assistants to keep a running V2-to-V3 SRN cross-walk per client portfolio for FY 2026-27. Flag any external-facing letter that quotes a V2 SRN as needing a V3 follow-up reference.
Gap 5: Schedule III / IGAAP attachments held only as scanned PDFs
Several clients filed AOC-4 attachments as scanned PDFs of physical sign-offs. The V3 portal validation is stricter on file size, OCR readiness, and attachment naming. A scanned PDF that passed V2 validation may fail V3 validation if it exceeds 6 MB or is image-only.
Fix: for every client where the FY 2024-25 AOC-4 was filed late in V2 with scanned attachments, regenerate the attachments as searchable PDF (OCR enabled) at under 6 MB. Use this as a dry run before the FY 2025-26 cycle.
The June 30, 2026 cutover playbook
- By Friday May 15, 2026: finish portfolio inventory. List every entity, its V2 pending items, its DSC re-registration status, and its historical export status. One row per entity; one tab per category.
- By Friday May 22, 2026: finish DSC migration for every active director, authorised signatory, and practising professional in the portfolio. No exceptions.
- By Friday May 29, 2026: finish all charge filings on V2 or commit to restarting on V3. The decision is binary; do not leave items in mid-workflow on V2.
- By Friday June 5, 2026: draft FY 2025-26 MGT-7 / MGT-7A / AOC-4 on V3 in trial mode for the top 5 clients in the portfolio. Surface schema mismatches.
- By Friday June 12, 2026: finish historical attachment exports per client. Off-portal repository ready.
- By Friday June 19, 2026: close every “Mark for resubmission” item on V2.
- By Friday June 26, 2026 close of business: all V2-only items signed and uploaded. After this date assume V2 is congested and unreliable.
- Monday June 29 to Tuesday June 30, 2026: final V3 smoke tests per client. Document any open items in writing for FY 2026-27 follow-up.
- Wednesday July 1, 2026: V2 read-only. Do not promise clients V2 access for fresh filings beyond this date.
What goes wrong if you defer past June 26, 2026
The risk is not theoretical. From the V2 to V3 transition pattern at MCA21, the last 96 hours of a major portal cutover routinely see portal congestion, DSC validation timeouts, and payment-gateway retries. The MCA help-desk volume spikes and turnaround on tickets stretches from the usual 48 hours to 7 to 10 days. A CHG-1 not signed and uploaded by June 26 may roll into July 1 as a re-filing on V3 with re-uploaded attachments, fresh DSC affixation, and a fresh fee. The 30-day statutory window under Section 77 does not pause for a portal cutover.
How this connects to other recent advisories
This piece is part of an emerging compliance trilogy with two other recent advisories on this site:
- Post 714 (April 28, 2026): the 9-week MCA21 V2 decommissioning migration checklist. Read it for the strategic framing and the V2 form retirement list.
- Post 718 (May 1, 2026): SBO electronic register on V3 portal effective April 1, 2026. Read it for the V3 SBO compliance load that arrives in parallel with the V2 cutover.
- Post 720 (May 1, 2026): ROC jurisdiction re-alignment 2026. Read it for the cross-cutting issue of which V3 ROC each entity now falls under.
Frequently Asked Questions
Q1: Is the June 30, 2026 cutover date final?
As of the date of this article, the MCA has not announced any extension. The June 30, 2026 cutover was confirmed in the original V2-to-V3 transition advisory. Practitioners should plan around June 30, 2026 as a hard date and treat any later extension as a bonus, not an assumption. Working to a September 30 backstop is what creates last-week congestion.
Q2: Will V2 SRN numbers remain valid for legal evidence after July 1, 2026?
Yes. A V2 SRN is a record of a filing made on V2 between 2006 and June 30, 2026. The number, the form, and the certified attachments remain valid evidence. After July 1, 2026 the V2 portal moves to read-only mode for lookup but the underlying records remain authentic. New filings starting July 1, 2026 generate V3-format SRNs.
Q3: Do I need to re-register a DSC on V3 if I never used it on V2?
If the DSC was never registered on V2, you can register it directly on V3 under the standard new-DSC association flow. The re-registration step is for DSCs already mapped to V2 user profiles which need to be re-associated with the corresponding V3 user profile.
Q4: What happens to a CHG-1 filed on V2 on June 30, 2026 but not yet approved?
A CHG-1 filed and accepted by the system on or before June 30, 2026 will move into the V2 pending-approval workflow. The MCA has indicated that V2 pending items will continue to be processed by RoC officers post-cutover, with the certificate issued on V3. Practitioners should still avoid this scenario where possible because it splits the workflow across two portals.
Q5: How do I find a complete list of V2 forms that are being retired?
The MCA has published the V2-to-V3 form mapping on the V3 portal under the FAQ section. Most operational forms (CHG-1/4/9, MGT-7/7A, AOC-4, DIR-3 KYC, INC-22, INC-22A) have direct V3 equivalents. A small set of legacy V2-only forms is being retired without a V3 equivalent; these are largely historical and rarely used in current practice.
Q6: Can I prepare FY 2025-26 MGT-7 on V3 now?
Yes. The V3 MGT-7 form is live and accepts FY 2025-26 data entry. The 60-day clock from the AGM date applies as usual under Section 92 of the Companies Act 2013. Drafting early in May or June surfaces any V3 schema differences while V2 is still available for cross-checks.
Practitioner takeaway
The decommissioning is not the kind of soft transition where a deferral note arrives at week 12 and rescues the back foot. The June 30, 2026 date has been on the calendar since the V2-to-V3 program was announced. Work the 53-day clock with a week-by-week sprint discipline. Inventory in week 7. DSCs in week 8. Charges in week 9. Trial annual returns in week 10. Historical exports in week 11. Resubmissions in week 12. Final V2 push in week 13. Smoke tests in week 14. Anything sitting on V2 at close of business on Friday June 26, 2026 should be assumed lost to a V3 re-filing.
Stay ahead of the V2-to-V3 cutover
The MCA21 transition is one of three compliance fronts running on the same June 30 to September 30 calendar. Sequence the V2 wind-down, the V3 SBO register, and the FY 2025-26 annual returns the right way and you avoid a last-week scramble.
Talk to an Expert. If you would like a portfolio-level read on V2 closure, V3 onboarding, and the V3 SBO mandate, schedule a quick call here. Tax Update India works with founders, CFOs, and CA portfolios on the operational arithmetic of these transitions.
Disclaimer: This article is for general information and is not a substitute for legal or professional advice. Verify the current MCA21 V3 portal documentation, the form mapping list, and the cutover communication on www.mca.gov.in before relying on the timeline. Tax Update India does not assume responsibility for any decision taken on the basis of this article.