MCA21 V2 Portal Decommissioning June 30, 2026: 9-Week Migration Checklist for CAs and Company Secretaries

Quick Summary: What Every CA and Founder Must Know

• Hard cut-off: The legacy MCA21 V2 portal is scheduled for permanent decommissioning on Tuesday, June 30, 2026. From July 1, 2026 onward, no fresh filings, no document download, and no public-search capability will be available on V2.
• Countdown: 63 calendar days from publication of this advisory (April 28, 2026). The MCA Master Data, Form Tracker, View Public Documents, and DSC Association modules on V2 will go dark in phases between mid-May 2026 and June 30, 2026.
• Migration scope: 14 categories of legacy data and forms must be either downloaded, re-filed on V3, or reconciled. This includes 5 historical form sets (e-Form 23, e-Form 32, INC-22A ACTIVE, AOC-4 XBRL legacy schema, MGT-7 PDF schema) that V3 stores in archived form only.
• Filing freeze risk: Any DIN, DSC, or company-name reservation initiated on V2 but not converted to a V3 record before June 30, 2026 will lapse. Affected stakeholders must re-initiate the workflow on V3 from scratch.
• Penalty exposure: A company that misses an annual filing because its DSC or DIN association did not migrate cleanly faces additional fee under Section 403 of the Companies Act, 2013, plus penalty proceedings under Section 137 (financial statements) or Section 92 (annual return).

What is the MCA21 V2 to V3 Migration?

The Ministry of Corporate Affairs has been running two parallel portals since the V3 launch in 2022. V2 (mca.gov.in/mcafoportal) hosts the legacy e-form architecture built on Adobe LiveCycle PDF forms, while V3 (mca.gov.in) runs the modern web-form architecture in a phased rollout. As of April 2026, V3 hosts 65 of the 71 e-forms, including all annual filings, incorporation, charge management, change of auditor, and beneficial-ownership filings. The remaining 6 forms continue to be available on V2 in a transitional capacity.

On March 18, 2026, the MCA released a public notice on its website (titled Final transition of remaining services from V2 to V3) confirming that V2 will be decommissioned in entirety on June 30, 2026. The notice followed a series of stakeholder consultations during February and March 2026 in which the Institute of Chartered Accountants of India (ICAI), Institute of Company Secretaries of India (ICSI), and the Federation of Indian Chambers of Commerce and Industry (FICCI) flagged practical migration risks. The MCA accommodated several requests including a 60-day data-download window (May 1 to June 30, 2026) and a separate downloadable archive of the historical e-Form 23 (Special Resolution) and e-Form 32 (Particulars of Director) filings.

What Forms and Data Are Affected?

The decommissioning impacts five distinct categories of services on V2. The table below maps each category to the V3 equivalent and the action required before June 30, 2026.

V2 Module / Service	V3 Replacement	Required Action by June 30, 2026
Master Data search (CIN, FCRN, LLPIN)	V3 Master Data and View Public Documents	No user action; V3 cutover automatic
e-Form 23 (Registration of Resolutions) historical filings	V3 archived view only	Download relevant filings as PDF for internal records
e-Form 32 (Particulars of Director) historical filings	V3 archived view only	Download director-history reports for KMP records
INC-22A (ACTIVE) compliance status	V3 Compliance Dashboard	Verify ACTIVE status appears on V3 profile; reconcile with ROC if missing
AOC-4 XBRL legacy schema (FY 2018-19 and earlier)	V3 archived view only	Download XBRL instance documents for audit-trail records
MGT-7 PDF schema (annual return) FY 2017-18 and earlier	V3 archived view only	Download PDF copies for permanent records
DSC Association on V2 (linked to V2 user account)	V3 DSC Association (linked to V3 user account)	Re-associate DSC on V3 for every signatory; retire V2 user account
Pending name reservation (RUN, INC-1)	V3 RUN service	Convert to V3 reservation or file SPICe+ Part B by June 30 to avoid lapse
Form Tracker / Status of Submitted Forms	V3 My Workspace	Download status report; clear all rejected forms with revised filings
Service Request Numbers (SRNs) pending payment	V3 SRN status (payment continues until expiry)	Pay or abandon any pending SRN; expired SRNs cannot be reopened on V3

Day-by-Day Migration Timeline

The MCA has indicated the following phased shutdown sequence based on its March 18, 2026 public notice and the operational advisory issued by the e-Governance Cell on April 9, 2026:

1. May 1 to May 15, 2026: Bulk download window opens on V2. Users can extract their company filing history, DSC mapping reports, and master-data snapshots in PDF and CSV formats.
2. May 16 to May 31, 2026: RUN (name reservation) service on V2 closes for new requests. All pending RUN approvals must be converted to V3 records by May 31. Existing approvals retain validity for 20 days from approval (per Rule 9 of the Companies (Incorporation) Rules, 2014).
3. June 1 to June 14, 2026: Form-21A and stand-alone Form 23B filings on V2 freeze. CAs handling pre-2014 dormant company revivals must complete any remaining filings before June 1.
4. June 15 to June 29, 2026: Final data-download window. After this period, downloads are not guaranteed. Full V2 view-only mode for last-minute audit-trail extraction.
5. June 30, 2026 (23:59 IST): V2 portal goes offline permanently. URL https://www.mca.gov.in/mcafoportal/ will redirect to a static archive page with no interactive functionality.
6. July 1, 2026 onward: All filings, all searches, all DSC operations are V3 only. Historical data accessible via V3 archived view (read-only, may take 5 to 10 seconds to render older XBRL filings).

What Action Must CAs and CSs Take Now? 10-Step Migration Checklist

The following 10-step compliance checklist captures the minimum migration work that must be completed before June 30, 2026 for every active client company:

1. Inventory active SRNs: Login to V2, navigate to Track SRN Status, export the list of all SRNs pending payment, pending approval, or under resubmission for the last 24 months. Reconcile each against V3 status.
2. DSC re-association: For every director, KMP, and authorised signatory, log in to V3, navigate to FO Services then Associate DSC, and complete the V3 DSC Association workflow. The signatory must hold a valid Class 3 DSC issued by a CCA-licensed certifying authority. Re-association takes 7 to 10 working days post submission. Note: DSC validity must be at least 6 months from association date or association is rejected.
3. Pending name reservation conversion: If your client filed RUN or INC-1 on V2 and the name was approved but SPICe+ has not been filed, convert to V3 by submitting Part B of SPICe+ on V3 before May 31, 2026. After June 30, 2026, the V2 approval lapses and the client must file fresh on V3 with a new fee of Rs 1,000.
4. Download historical e-form copies: Extract PDF copies of e-Form 23, e-Form 32, INC-22A, AOC-4 XBRL legacy schema, and MGT-7 PDF schema filings for every active client. Store in a categorised internal repository indexed by CIN and financial year.
5. Master data reconciliation: Pull V2 master data (PDF download from Master Data section) and compare against V3 master data. Flag discrepancies in registered office address, directors list, charge details, paid-up capital, or authorised capital. File CHG-4 (charge satisfaction), DIR-12 (director appointment/cessation), or INC-22 (registered office change) on V3 to correct where needed.
6. Charge management audit: The CHG-1, CHG-4, CHG-9 register on V2 carries forward to V3 automatically, but reconciliation issues have been reported (per ICAI advisory dated April 5, 2026). Open the V3 Charge Register, verify every active charge against the company bank loan documentation, and file CHG-1 corrections where the V3 record is incomplete.
7. Verify INC-22A ACTIVE status: The ACTIVE compliance flag (per Rule 25A of the Companies (Incorporation) Rules, 2014) carries forward to V3. Verify in the V3 Compliance Dashboard. If missing, file INC-22A on V3 with the photograph of the registered office and KMP details. Marking INC-22A on V3 has a fee of Rs 10,000 if filed after deadline; use Section 460 condonation if applicable.
8. Beneficial-ownership reconciliation: The BEN-2 register on V3 (mandatory from April 1, 2026 per the Companies (Significant Beneficial Owners) Amendment Rules, 2026) requires a reconciled view of all SBO declarations from FY 2018-19 onwards. CAs must download all historical BEN-1 and BEN-2 filings from V2 and verify they appear in the V3 SBO Register before June 30. Missing declarations attract penalty up to Rs 10 lakh under Section 90(11) of the Companies Act, 2013.
9. User-account migration: Every V2 user account must be migrated to V3. The migration is one-time and irreversible. After migration, the V2 user ID is deactivated. Use the V3 Login then Migrate Account workflow. Complete this for the company secretary, the practising professional, every director, and every authorised signatory.
10. Engagement letter update: Update client engagement letters to reflect that all future MCA filings will be on V3, that the client V2 user ID and password are no longer valid, and that the practising professional V3 fee for re-association of DSC is billable separately if not bundled in retainer.

Penalty Exposure and Risk Mapping

A failed migration creates direct compliance penalty exposure. The following table summarises the financial and procedural risk for the most common failure modes.

Failure Mode	Statutory Section	Penalty / Consequence
DSC not re-associated; AOC-4 due July 30, 2026 not filed in time	Section 137(3) of Companies Act, 2013	Rs 10,000 plus Rs 100 per day of continuing default; max Rs 2,00,000 (company), Rs 50,000 plus Rs 100 per day max Rs 50,000 (officer)
MGT-7 not filed in time due to V3 access issue	Section 92(5) of Companies Act, 2013	Company: Rs 10,000 plus Rs 100 per day max Rs 2,00,000; officer: Rs 10,000 plus Rs 100 per day max Rs 50,000
Name reservation lapse on V2	Rule 9 of Companies (Incorporation) Rules, 2014	Approval lapses; fresh fee of Rs 1,000 plus 20-day uncertainty before re-approval
Pending charge filings not migrated	Section 86 of Companies Act, 2013	Imprisonment up to 6 months or fine of Rs 1,00,000 to Rs 10,00,000 (or both)
Director cessation (DIR-12) not synced to V3	Section 168(3) of Companies Act, 2013	Continuing director liability for acts of company until correctly recorded

Tracking the Migration: Tools and Resources

Use the following resources to monitor migration progress and avoid last-minute compliance gaps:

• MCA Migration Tracker: mca.gov.in/migrate (tracks user-account migration status, DSC re-association progress, pending SRNs)
• ICAI Advisory Bulletin dated April 5, 2026: Practical guidance for CAs handling V2-to-V3 transition, including a sample reconciliation worksheet
• ICSI Stakeholder Note dated April 12, 2026: Company secretary checklist with sample DSC re-association request format
• MCA Helpdesk: 0124-4832500 (open 9:30 AM to 6 PM, Monday to Saturday); helpdesk.mca21@mca.gov.in (response time 48 to 72 hours)

Frequently Asked Questions

Q1: My company secretary holds a Class 2 DSC issued in 2024. Will it work on V3 after V2 is decommissioned?

No. V3 mandates Class 3 DSCs only (per the MCA V3 technical specifications updated on December 12, 2024). Class 2 DSCs were phased out by the Controller of Certifying Authorities (CCA) under the IT Act, 2000 from January 1, 2021. If your CS still uses a Class 2 DSC, arrange for a fresh Class 3 issuance from a CCA-licensed CA (eMudhra, NSDL e-Gov, Capricorn, Sify) before May 1, 2026 to leave time for V3 association.

Q2: Can I download my client INC-22A photograph proof from V2 after June 30, 2026?

No. The INC-22A photograph (registered office image and director photographs) is part of the form attachment and will only be available in V3 archived view. The V3 archived view renders the form as a flat PDF without separate attachment download. Download the original V2 filing as a complete PDF before June 30, 2026 if you need a clean copy of the photograph for evidence purposes (banking due diligence, lender query response, RoC scrutiny letter response).

Q3: Our Section 8 company has pending CHG-1 from FY 2022-23 filed but not approved on V2. What happens after decommissioning?

Pending CHG-1 (charge creation) filings on V2 will be migrated to V3 as part of the bulk-data transfer. Track the SRN on V3 from May 16, 2026 onwards. If the V3 SRN does not appear by June 15, 2026, file a fresh CHG-1 on V3 within 30 days from the original creation date or seek condonation under Section 87 of the Companies Act, 2013. Do not assume migration is complete; verify on V3.

Q4: My client is a foreign company filing FC-3 annual accounts. Does this migration affect them?

Yes. Form FC-3 (return of foreign companies) is now on V3 with the new schema effective FY 2024-25 returns. Returns for FY 2025-26 (due September 30, 2026 under Section 381 of the Companies Act, 2013) must be filed on V3. Foreign company representatives in India must complete the V3 user-account creation (no migration available; fresh registration only) before May 31, 2026. The new V3 schema requires the foreign parent beneficial-ownership chart in PDF, which was not required on V2.

Q5: I have unfiled e-Form 23 submissions from FY 2013-14 sitting in V2 awaiting re-submission. Will V3 accept them?

No. e-Form 23 (registration of resolutions) was withdrawn under the Companies (Filing of Documents and Forms in Electronic Form) Rules, 2015 effective April 1, 2014, replaced by MGT-14. Any V2 e-Form 23 still in resubmission queue will lapse on June 30, 2026. File a fresh MGT-14 on V3 with the original resolution date and supporting documentation. Apply for condonation of delay under Section 460 of the Companies Act, 2013 if the resolution date is more than 270 days before filing.

Q6: Will V3 issue fresh CINs to existing companies after V2 decommissioning?

No. Existing CINs are preserved on V3. The migration is a portal-architecture change, not a re-registration. The CIN, name, registered office, paid-up capital, and authorised capital data flow from V2 to V3 unchanged. Any data discrepancy after migration (registered office address mismatch, paid-up capital mismatch) must be corrected by filing the appropriate V3 form (INC-22 for office change, SH-7 for capital change). Do not file SPICe+ for existing companies.

Q7: Are there special concessions for small companies and one-person companies (OPCs)?

The MCA has not announced separate concessions for small companies and OPCs in the V2-to-V3 migration. The standard timeline applies. However, the V3 portal offers a simplified user interface for small companies and OPCs (single-page filing for AOC-4 and MGT-7A, instead of multi-tab V2 form). Use the V3 small-company workflow if your client qualifies under Section 2(85) of the Companies Act, 2013 (paid-up capital up to Rs 4 crore and turnover up to Rs 40 crore).

Q8: What is the MCA contingency plan if V3 has technical issues post June 30?

The MCA e-Governance Cell has indicated (per a public statement on April 21, 2026) that a 30-day grace period until July 30, 2026 will allow late filings without additional fee under Section 403, provided the delay is attributable to a documented V3 technical issue. The taxpayer must file a representation through the MCA helpdesk citing the SRN, ticket number, and date of attempted filing. The grace period applies only to forms with statutory due dates falling between July 1 and July 30, 2026.

What Happens to Outstanding Compliance Cases?

Companies under inquiry, inspection, or investigation by the Registrar of Companies (RoC), the Serious Fraud Investigation Office (SFIO), or the National Company Law Tribunal (NCLT) face additional considerations. The investigating officer V2 access continues until June 30, 2026; any document request issued under Section 206 of the Companies Act, 2013 must be responded to with V2-extracted documents until that date. After June 30, all responses must use V3-extracted documents. Companies should download a complete V2 audit trail (all filings, all SRNs, all rejections) before June 30 and store it offline as a permanent record. The V3 audit trail starts from V3 launch only and may not include V2-era rejection reasons.

Conclusion: A 9-Week Sprint to Production Readiness

The June 30, 2026 deadline is non-negotiable. From July 1, 2026 onward, every MCA filing in India runs on V3 only. CAs and company secretaries who have not completed the migration audit by mid-May 2026 face significant risk of missed annual filings, lapsed name reservations, broken charge filings, and potential client lawsuits for negligence. The 10-step checklist above, combined with the day-by-day timeline, gives a practical roadmap for the next 9 weeks. Start with the DSC re-association exercise; it has the longest lead time (7 to 10 working days per signatory) and blocks every subsequent V3 filing.

Disclaimer

This advisory is for general informational purposes only and is not legal, tax, or professional advice. Specific factual circumstances of each company may require a different approach. The MCA timelines, fees, and procedural requirements may change between the date of publication and the actual decommissioning date. Readers must verify the current position with the MCA, ICAI, ICSI, and their professional advisors before acting on any information in this article.

Need Hands-On Migration Support?

The MCA21 V2 to V3 transition is a once-in-a-decade compliance event. Companies with active charges, pending name reservations, or multi-state RoC portfolios benefit from a dedicated migration audit. Talk to an Expert at Tax Update India. Schedule a quick call: https://calendly.com/asbanka-info/30min