DIN KYC Compliance in India

To strengthen governance and eliminate fictitious directorships, the Ministry of Corporate Affairs (MCA) now mandates an annual KYC exercise for all active and disqualified company directors. This requirement, introduced via Rule 12A in the Companies (Appointment and Qualification of Directors) Rules, 2014, compels every individual holding a Director Identification Number (DIN) or Director Partner Identification Number (DPIN) to file their KYC electronically each financial year.

What Is a Director Identification Number (DIN)?

A DIN is a unique, eight-digit number issued by the Central Government to any person intending to serve as a company director. Prospective directors must apply through e‑Form DIR‑3, accompanied by the prescribed fee and supporting documents, to secure their DIN.

Annual Director KYC Process

Rule 12A, effective 10 July 2018, stipulates:

1. Who Must File:
   Every individual with an active DIN/DPIN as of 31 March of a financial year.
2. Deadline:
   Submit e‑Form DIR‑3 KYC by 30 September of the immediately following financial year.
3. Initial Compliance:
   Directors holding a DIN/DPIN on 31 March 2018 had until 5 October 2018 to file their first KYC return.
4. Subsequent Filings:
   Those who previously filed DIR‑3 KYC shall use web‑form DIR‑3 KYC‑WEB for all later years, fulfilling the annual requirement.
5. Updating Contact Details:
   To change a registered mobile number or email, directors must submit e‑Form DIR‑3 KYC with the updated information.

Non‑compliance attracts disqualification and penalties under the Companies Act, reinforcing director accountability and transparency.

Key Highlights of the Annual DIN KYC Requirement

Under Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014, every person holding a Director Identification Number (DIN) or Director Partner Identification Number (DPIN) as of March 31 in any financial year must complete the DIN KYC exercise before September 30 of the same year.

• Repeat Filers with No Changes:
  If you filed the DIR‑3 KYC form in the previous financial year and have no updates to your personal information, you simply log in to the MCA’s web service and submit the DIR‑3 KYC‑WEB form.
• Updating Mobile Number or Email:
  Should you need to change your registered mobile number and/or email address, you must file the traditional e‑Form DIR‑3 KYC, providing the new contact details.
• Other Personal Data Changes:
  For any other amendments to your personal particulars—such as name, address, or identification details—first submit e‑Form DIR‑6 to update those fields. Once DIR‑6 is processed, you may then complete your annual KYC via DIR‑3 KYC‑WEB.

Deadline and Penalties
All KYC submissions—whether via DIR‑3 KYC or DIR‑3 KYC‑WEB—are due by September 30 following the March 31 cut‑off. For instance, directors with a valid DIN/DPIN on March 31, 2021, were required to complete their KYC by September 30, 2021.

Failure to comply by the deadline triggers a penalty of ₹5,000 to restore the “Approved” status of your DIN, unless the MCA announces a fee waiver scheme.

Note: Even directors whose DIN has been disqualified must fulfill this annual KYC requirement to maintain regulatory compliance.

How to File Your Annual DIN KYC

Each director whose Director Identification Number (DIN) or Director Partner Identification Number (DPIN) is active as of March 31 must complete the KYC process by September 30. There are two distinct routes, depending on whether you are updating existing details or filing for the first time:

1. Web‑Based DIR‑3 KYC (No Changes to Personal Details)

If you filed e‑Form DIR‑3 KYC in the previous year and have no updates to your personal information, simply log in to the MCA portal and follow these steps:

1. Visit the MCA website: mca.gov.in
2. Log in with your credentials.
3. Navigate to MCA Services → DIN Services → DIR‑3 KYC WEB.
4. Enter your DIN and click Submit.
5. Generate OTPs for your registered mobile number and email.
6. Enter the OTPs in the required fields to verify contact details.
7. Review and approve the pre‑filled personal information on screen.
8. Click Submit, then Generate Zero‑Rupee Challan.
9. Note the Service Request Number (SRN) to track your KYC status.

2. e‑Form DIR‑3 KYC (First‑Time Filing or Contact Updates)

Any director filing for the first time—or wishing to update a mobile number or email address—must submit e‑Form DIR‑3 KYC:

Prerequisites & Attachments:

• Digital Signature Certificate (mandatory)
• Identity Proof: PAN, Aadhaar, Passport (and optionally Driver’s License)
• Proof of Permanent Address (self‑attested)
• Proof of Present Address (if different)
• Professional Certification: Signed by a practicing CA/CS/CMA with their details

Filing Steps:

1. Download e‑Form DIR‑3 KYC from mca.gov.in.
2. Enter your DIN, personal details (name, nationality, date of birth), and contact information.
3. Upload all required attachments, ensuring each is self‑attested.
4. Verify your PAN and generate OTPs for your mobile and email.
5. Digitally sign the form with your DSC and the certificate details of the signing professional.
6. Submit the form and note the SRN.
7. Await email confirmation of approval.

Checking Your KYC Status & Consequences of Non‑Filing

• Status “Approved” (or “Active”) appears once your DIR‑3 KYC (e‑form or web form) is successfully filed by September 30 each year.
• Status “De‑Activated” will be shown if you miss the deadline.
• A de‑activated DIN/DPIN prohibits you from filing any director‑related e‑forms that pull your DIN data automatically (e.g., DIR‑12 for appointment/resignation filings).
• Note: De‑activation does not invalidate your director actions or your appointment; it merely blocks further MCA filings until you re‑activate your DIN by completing the KYC process.

By following these steps and observing deadlines, directors ensure their DIN remains in “Approved” status, maintaining full compliance and uninterrupted ability to file necessary MCA returns.

Penalty for Non-Filing of DIN KYC

While there is no separate penalty prescribed for non-compliance with DIN KYC, the MCA mandates a late filing fee of ₹5,000 for delayed submission of e-Form DIR-3 KYC or web-form DIR-3 KYC-WEB beyond the due date of 30th September.

Until the filing is completed and the fee is paid, the DIN remains “Deactivated due to non-filing of KYC”, which restricts the ability of the director to file any further forms where an active DIN is required.

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