Form DPT-3: Return of Deposits Filing Guide
Form DPT-3 is a mandatory annual return filed by companies to report outstanding loans, borrowings, and other monies received that are not classified as “deposits” under the Companies Act. Every company - including those with nil outstanding amounts - must file by 30 June each year.
What Is Form DPT-3?
DPT-3 is filed under Rule 16 of the Companies (Acceptance of Deposits) Rules, 2014. It captures the outstanding balance of any sum received by the company that is not a “deposit” as defined under the rules - typically loans from directors, shareholders, relatives of directors, inter-corporate loans, and loans from financial institutions.
The form serves as a compliance monitoring tool. Regulators use DPT-3 to track corporate borrowings, detect circular financing arrangements, and identify companies that may be disguising public deposits as exempt inter-party loans.
Nil return is also mandatory
Even if a company has no outstanding loans or exempt amounts as on 31 March, a nil DPT-3 must still be filed by 30 June. Non-filing of a nil return attracts the same penalties as non-filing when amounts are outstanding.
Who Must File?
All companies registered under the Companies Act 2013 must file DPT-3, with the following exclusions:
- Government companies (i.e., companies where the Central or State Government holds 51% or more)
- Banking companies regulated under the Banking Regulation Act 1949
Private companies, public companies, OPCs, Section 8 (non-profit) companies, and foreign companies with Indian subsidiaries are all required to file.
What to Include
DPT-3 captures the position as on 31 March of the immediately preceding financial year. For each outstanding amount, the following details must be reported:
- ✓Lender name and PAN
- ✓Nature of the amount (director loan, shareholder loan, inter-corporate deposit, etc.)
- ✓Outstanding principal amount as on 31 March
- ✓Rate of interest (if any)
- ✓Repayment terms and tenure
- ✓Date on which the amount was received
- ✓Whether the amount is secured and, if so, nature of the security
- ✓Auditor certificate - mandatory for outstanding amounts exceeding ₹1 crore
Due Date
DPT-3 must be filed by 30 June each year, reporting outstanding amounts as on the preceding 31 March. For the financial year ending 31 March 2026, the due date is 30 June 2026.
30 June
Annual due date
Reports position as on 31 March
₹100/day
Late fee accrual
Per day after due date
₹1 crore
Auditor certificate threshold
Required if outstanding exceeds this
Penalties for Non-Filing
Non-filing of DPT-3 attracts penalties at multiple levels:
- Daily late fee: ₹100 per day from the due date.
- Company-level fine: Minimum ₹1 crore or twice the amount of deposits involved, whichever is lower, up to a maximum of ₹10 crore.
- Officer-level fine: Every defaulting officer (typically all directors and the CFO) faces the same fine as the company plus up to 7 years of imprisonment in the most serious cases.
These are among the highest penalties under the Companies Act
The deposit-related penalties under the Companies Act are intentionally severe because accepting unregistered public deposits is treated as a serious financial offence. Even an inadvertent non-filing of DPT-3 triggers these provisions.
Partial Exemptions for Private Companies
Private companies that satisfy all the following conditions are exempt from reporting certain director and shareholder loans in DPT-3: the company has not committed a default in repaying deposits or debentures; it has not issued any advertisement or circular inviting deposits; and it has not violated Section 73 or Section 76 at any time in the three years preceding the filing.
Even if the director/shareholder loan exemption applies, the private company must still file DPT-3 for all other outstanding amounts (inter-corporate loans, bank loans used as collateral, etc.) and must still file a nil return if all amounts are exempt.
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