What is the purpose of DPT 3 Filing?
Filing DPT-3 builds transparency and accountability in a company's financial dealings. By making this information public, it strengthens trust and demonstrates responsible management of deposit-related activities:
- A primary goal of filing DPT-3 is to notify the Registrar of Companies about deposits received throughout the financial year. This ensures transparency by providing regulators with a complete record of the company's deposit activities.
- In addition to deposits, Rule 16 mandates that form DPT-3 also record receipts the company doesn't classify as deposits (such as outstanding loans). This comprehensive reporting ensures a complete and accurate picture of the company's annual financial activities.
Who must file Form DPT-3?
Form DPT-3 generally applies to companies that have reportable deposits or specified outstanding amounts. The filing requirement can apply even when a company has not accepted deposits. Companies should assess their liabilities as of March 31 to determine applicability.
| Company or entity | DPT-3 filing requirement |
| Private companies | Yes, if reportable amounts exist |
| Public companies | Yes, if reportable amounts exist |
| One-Person companies | Yes, where applicable |
| Small companies | Yes, where applicable |
| Listed companies | Yes, where applicable |
| Unlisted companies | Yes, where applicable |
| Banking companies | No |
| RBI-registered NBFCs | No |
| Housing Finance Companies registered with NHB | No |
| Government companies | No |
Key point: DPT-3 may apply without accepting deposits. Companies should review qualifying borrowings and receipts before filing.
Who is required to file DPT-3?
All companies except government-owned companies must file this return.
Who is exempt from filing the return?
The following companies are exempt under Rule 1(3) of the Companies (Acceptance of Deposits) Rules 2014:
- Banking companies
- Non-Banking Financial Companies (NBFCs)
- Housing finance companies registered with the National Housing Bank
- Any other company exempted under the proviso to subsection (1) of section 73 of the Act.
Additional read: What is Form 19 in EPFO
Form DPT 3 due date
The due date for submitting Form DPT-3 is June 30th each year. Companies must report all deposits and outstanding non-deposit receipts for the financial year ending on March 31st.
Key points:
Example:
For the 2023-24 financial year (April 1, 2023 - March 31, 2024), the deadline for DPT-3 submission is June 30, 2024.
Types of returns under Form DPT-3
Form DPT-3 provides different filing categories based on the nature of amounts and transactions reported. Selecting the appropriate category helps companies report their outstanding liabilities accurately.
| Filing category | Purpose |
| Return of deposits | Reports amounts that qualify as deposits under the Companies Act, 2013. |
| Return of transactions not considered deposits | Reports specified outstanding amounts excluded from the definition of deposits under applicable rules. |
| Return of deposits and exempted deposits | Covers both qualifying deposits and reportable exempted amounts. |
| One-time return | Relates to the historical reporting requirement introduced through applicable amendments. |
Deposits vs. exempted deposits: What companies must report?
Companies should distinguish between deposits and exempted deposits before preparing Form DPT-3. The classification depends on the nature and source of funds received.
| Features | Deposits | Exempted deposits |
| Basic meaning | Amounts that fall within the statutory definition of deposits. | Amounts specifically excluded from the deposit definition under applicable rules. |
| Typical sources | Certain public or shareholder deposits and qualifying customer advances. | Directors, eligible relatives, banks, financial institutions, companies and government authorities. |
| Regulatory treatment | Subject to applicable deposit acceptance and compliance requirements. | Not treated as deposits when prescribed conditions are satisfied. |
| Form DPT-3 relevance | Reportable where applicable. | Certain exempted amounts are also required to be reported. |
| Key consideration | Companies must verify whether the receipt satisfies the deposit definition. | Companies must confirm that the specific exemption and its conditions apply. |
2026 insight: A transaction being exempt from the deposit definition does not automatically mean it is excluded from DPT-3 reporting.
Transactions not considered deposits under DPT-3
- Government-sourced funds: Any amount received from a government (domestic or foreign bank) or backed by a government guarantee.
- Loans from specific institutions: Loans or facilities from Public Financial Institutions, Insurance Companies, or Banks.
- Inter-company transactions: Amounts received from another company.
- Securities and advances: Subscription payments for securities or calls in advance.
- Director-related funds: Amounts received from a director of a private company, or a relative of a director, who held that position when the funds were provided.
- Employee deposits: Amounts received from an employee, up to their annual salary, as part of an employment agreement (e.g., non-interest-bearing security deposit).
- Business-related advances: Funds received as an advance payment for providing goods or services, or as a performance security deposit for a related contract.
- Startup convertible notes: An amount of Rs. 25 lakh or more received by a startup company through a convertible note in a single payment.
- Specific bonds/ debentures: Funds raised by issuing:
- Secured bonds or debentures with first charge
- Non-convertible debentures without a charge on company assets
- Promoter loans: Unsecured loans provided by promoters.
- Funds from regulated entities: Amounts received from:
- Nidhi Companies
- Chits under the Chit Funds Act, 1982
- Collective investment schemes, alternative investment funds, or mutual funds registered with SEBI
- Other Exemptions: Any amount explicitly not classified as a deposit under Rule 2(1)(c).
Documents required for DPT-3 filing
When submitting Form DPT-3, you need to include the following documents:
- A certificate from an auditor.
- Proof of the trust deed.
- Include the instrument that legally creates a charge (if any).
- Provide specific information about your company's liquid assets.
Additional read: What is Form 16a
Fees for filing form DPT-3
| Category | Details |
|---|
| Normal Filing Fee | The filing fee for Form DPT-3 depends on the company’s nominal share capital. Higher authorised capital attracts higher fees, as prescribed under the Companies (Registration Offices and Fees) Rules. |
| Additional Fees in Case of Delay in Filing Web Forms | If Form DPT-3 is filed after the due date, additional fees are charged based on the number of days delayed. The longer the delay, the higher the penalty, calculated as per MCA guidelines. |
Consequences of non-filing
Failure to comply with DPT-3 requirements while continuing to accept deposits can lead to serious penalties:
- Under Section 73: The company may face a minimum penalty of Rs. 1 crore or twice the amount of deposits, whichever is less, going up to Rs. 10 crore. Officers in default can face imprisonment up to 7 years and a fine ranging from Rs. 25 lakh to Rs. 2 crore.
- Under Rule 21: Both the company and responsible officers may be fined up to Rs. 5,000. If the non-compliance continues, an additional Rs. 500 per day is charged until rectified.
While there’s no clear mandate
Conclusion
Understanding the DPT-3 filing requirements is crucial for companies striving to maintain transparency and regulatory compliance. By accurately recording deposits, loans, and exemptions, businesses demonstrate their commitment to responsible financial practices. It is important for relevant companies to consult the official MCA guidelines and, if necessary, seek professional advice to ensure they fully understand and meet the DPT-3 filing obligations.
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