What a compliance calendar actually needs: RBI, SEBI and the labour codes

Why is a list of due dates not a compliance calendar?

Most compliance calendars start life as a spreadsheet of dates copied from a consultant's annual chart. That works for a year. Then the AGM moves, a regulator consolidates its circulars, a subsidiary is incorporated, or a filing deadline is changed, and nobody knows which rows depend on what.

The difference between a calendar and a list is that every date in a calendar is derived from something. The annual return is not "due 29 November"; it is due sixty days after the AGM, and the AGM itself has a statutory window. Store the rule and the anchor, and the date follows. Store only the date, and it is wrong the first time the anchor moves.

What does the Companies Act put on the calendar every year?

For most companies the annual cycle is anchored on the AGM. Section 96 of the Companies Act, 2013 requires every company other than a One Person Company to hold an AGM each year, within six months of the close of the financial year (nine months for the first AGM), with no more than fifteen months between one AGM and the next. The Registrar may extend the deadline by up to three months for a special reason, except for the first AGM.

Two filings run off the AGM date. Section 137 requires the adopted financial statements to be filed with the Registrar within thirty days of the AGM, in practice on form AOC-4. Section 92(4) requires the annual return to be filed within sixty days of the AGM, in practice on form MGT-7 or MGT-7A, or within sixty days of the date by which the AGM should have been held if none was held. Section 92(5) sets a penalty for late filing of the annual return of ten thousand rupees plus one hundred rupees a day, capped at two lakh rupees for the company and fifty thousand rupees for an officer in default.

These are the filings every company has. Board meetings, director disclosures, deposit returns, MSME returns and event-driven forms come on top, and depend on the company's facts.

What does SEBI's LODR require of a listed company on a recurring basis?

The SEBI (Listing Obligations and Disclosure Requirements) Regulations, 2015 carry the periodic cycle for companies with listed specified securities. Since SEBI's circular of 31 December 2024 introduced Integrated Filing, several of those filings are bundled:

• Integrated Filing (Governance): within 30 days of the end of each quarter. It covers the statement on redressal of investor grievances under regulation 13(3) and the compliance report on corporate governance under regulation 27(2)(a).
• Integrated Filing (Financial): within 45 days of the end of each quarter other than the last, and within 60 days of the end of the last quarter and the financial year. It covers financial results under regulation 33(3), the statement of deviation under regulation 32(1), quarterly disclosure of outstanding defaults, and the half-yearly related-party disclosure under regulation 23(9).
• Shareholding pattern under regulation 31(1)(b): quarterly, within 21 days of the end of each quarter, outside the integrated filing.
• Secretarial compliance report under regulation 24A(2): annually, within 60 days of the end of the financial year.

What do RBI-regulated entities have to file?

RBI's Master Direction on Filing of Supervisory Returns, issued on 27 February 2024, consolidated the supervisory-return instructions for commercial banks (excluding Regional Rural Banks), primary urban co-operative banks, select all-India financial institutions, NBFCs other than housing finance companies, and asset reconstruction companies. Returns are filed through RBI's Centralised Information Management System (CIMS).

The Direction harmonised default timelines by frequency: monthly returns within 15 days of the reference date, and quarterly, half-yearly and annual returns within 21 days, unless a return has an alternate timeline listed in its Annex IV. Audited returns are to be filed within five working days of the auditor's report being signed. Which returns apply depends on the type of entity and, for NBFCs, on its layer under scale-based regulation, so the list for a given entity has to be built from the Direction's Annex III rather than copied from another company.

RBI has also been consolidating its directions more broadly, so confirm on rbi.org.in which direction currently governs your returns before relying on any summary, this one included.

Where do the four labour codes stand?

The Code on Wages, 2019, the Industrial Relations Code, 2020, the Code on Social Security, 2020 and the Occupational Safety, Health and Working Conditions Code, 2020 were made effective from 21 November 2025, replacing 29 central labour laws. The Government's release said that during the transition, the relevant provisions of the existing Acts and their rules, regulations, notifications, standards and schemes continue in force.

Draft central rules were pre-published on 30 December 2025, and final central rules under the four Codes were notified in May 2026. Central rules apply where the Central Government is the appropriate government. For most private establishments the appropriate government is the state, and states are at different stages with their own rules.

For the calendar, this means every labour-law row needs a tag for which regime it comes from: a legacy Act still operating under the transition, a Code with central rules, or a Code with state rules. Without that tag, there is no way to tell which rows to retire when a state notifies its rules.

What fields does each calendar entry need?

Every entry, whichever regulator it comes from, should carry:

• The obligation in plain words, and the citation: Act, section or regulation, and the circular or notification that set the current timeline.
• The legal entity it binds. In a group, the same obligation applies separately to each company, and in some cases to each establishment or site.
• The due-date rule and its anchor: days after quarter end, days after AGM, on an event. Undated or event-driven obligations should be stored as such, not given an invented date.
• An owner who does the work and a reviewer who checks it, with an escalation path if neither acts.
• The evidence of discharge: acknowledgement number, challan, filed form. A calendar entry marked done without evidence is a claim, not a record.
• A last-reviewed date and a link to the source, so stale rows are visible.

How should a calendar handle regulatory change?

Treat change as a normal event, not an exception. The integrated filing changed several LODR timelines at once; the labour codes are replacing a whole regime; RBI consolidated its supervisory-return instructions into one direction. Each of those should have produced a reviewed change to specific rows, with the old rule retired on a date and the new one starting.

The test of a calendar is simple. Pick any row, and ask why that date is the due date and how you know the rule is current. If the answer is "the consultant's chart said so", the calendar is a list. If the answer is a citation and a last-reviewed date, it is a register you can defend in an audit.