“Strong governance builds strong institutions. Let’s Grow together in FY 2025-2026.”
G.V. and Associates, Company Secretaries & Advisory Solutionz (P) Ltd.
In this Issue (Updates for 01.11.2025 – 30.11.2025):
Compliance Calendar • Companies Act • Securities and Exchange Board of India • Reserve Bank of India • Income Tax & GST • Digital Personal Data Protection Rules • Labour Codes • Insolvency & Bankruptcy
Compliance Calendar For The Month Of December 2025
| Act | Form /<br>Regulation (Reg) No. | Applicability | Due Dates |
|---|---|---|---|
| Companies Act, 2013 | AOC 4 | All companies registered under the Companies Act, 2013. | WITHIN 31.12.2025 |
| AOC-4 XBRL | Indian companies that are listed on a stock exchange and their Indian subsidiaries, or companies with paid-up capital of ₹5 crore or more, or companies with an annual turnover of ₹100 crore or more | WITHIN 31.12.2025 | |
| AOC 4 CFS | Indian companies with one or more subsidiaries or associates | WITHIN 31.12.2025 | |
| PAS – 6 | All Public Companies and Applicable Private Companies | WITHIN 31.12.2025 | |
| MGT – 7 | All companies registered under the Companies Act, 2013 | WITHIN 31.12.2025 | |
| As per the MCA Circular dated 17.10.2025, the due date for filing Form AOC-4, AOC-4 XBRL, AOC-4 CFS, and MGT-7A has been extended till 31.12.2025 without any additional fee. | As per the MCA Circular dated 17.10.2025, the due date for filing Form AOC-4, AOC-4 XBRL, AOC-4 CFS, and MGT-7A has been extended till 31.12.2025 without any additional fee. | As per the MCA Circular dated 17.10.2025, the due date for filing Form AOC-4, AOC-4 XBRL, AOC-4 CFS, and MGT-7A has been extended till 31.12.2025 without any additional fee. | As per the MCA Circular dated 17.10.2025, the due date for filing Form AOC-4, AOC-4 XBRL, AOC-4 CFS, and MGT-7A has been extended till 31.12.2025 without any additional fee. |
| Foreign Exchange Management Act | ECB-2 | LLP & Company having ECB | WITHIN 07.12.2025 |
| Goods and Services Tax | PMT‑06 (QRMP monthly payment) | Monthly tax payment for November 2025 by QRMP scheme taxpayers. | WITHIN<br>25.12.2025 |
| Goods and Services Tax | GSTR-1 IFF | For QRMP taxpayers | WITHIN 13.12.2025 |
| Insolvency and Bankruptcy Board of India | Form VL | As may be Applicable | WITHIN 10.12.2025 |
| Insolvency and Bankruptcy Board of India | Form CP | As may be Applicable | WITHIN 10.12.2025 |
| Insolvency and Bankruptcy Board of India | Form LIQ | As may be Applicable | WITHIN 10.12.2025 |
Companies Act
Ministry of Corporate Affairs – Union Minister Chairs Review Meeting with Regional Directorates and ROCs
- Union Minister for Finance and Corporate Affairs Smt. Nirmala Sitharaman chaired a meeting on 25.11.2025 to review the Regional Directorates and Registrar of Companies, in New Delhi. The review meeting was also attended by Union Minister of State for Corporate Affairs Shri Harsh Malhotra; Secretary, Ministry of Corporate Affairs (MCA); along with all the senior officers of MCA and all the subordinate offices under MCA.
- During the meeting, detailed interactions and discussions were held with Registrar of Companies (ROCs) and Regional Directorates (RDs) on issues of processing of forms, fast track mergers, delivery of services like incorporation/voluntary exit of Companies/LLPs through the Central Facilities, e-governance, harmonisation of forms, matters related to adjudication, inquiries, inspection and investigation (3Is) manuals, prosecution, appeals against adjudication orders, compounding of violations etc.
Source: https://www.pib.gov.in/PressReleasePage.aspx?PRID=2194348
SFIO Institutes Safeguards to Prevent Misuse of Summons and Notices
The Serious Fraud Investigation Office (SFIO), established under the Companies Act, 2013, investigates and prosecutes complex corporate frauds assigned under Section 212 of the Companies Act. During the course of investigation, Summons/Notices are issued by the Serious Fraud Investigation Office (SFIO) as per the provisions of Section 217 of the Companies Act, 2013. In this context, SFIO has instituted the following set of technical and procedural safeguards on 21.11.2025 to prevent impersonation or misuse of Summons/Notices. Summons/Notices issued by SFIO are digitally generated and contain a QR code and a unique document identification number (DIN). The officers of SFIO are mandated to issue only digitally generated Summons/Notices except in certain rare and exceptional circumstances.
The system of online verification of Summons/Notices issued by SFIO is put in place to help the receiver to instantly verify the authenticity of the communication received. These verification systems have been put in place to give citizens immediate assurance that any communication they receive is genuine and to prevent impersonation or misuse. Further, to enhance oversight, a transparent multi-layer review mechanism is in place at SFIO to oversee the issuance of Summons and Notices.
Source: https://www.pib.gov.in/PressReleasePage.aspx?PRID=2192445
Securities And Exchange Board Of India
Specification of the terms and conditions for Debenture Trustees for carrying out activities outside the purview of SEBI
On October 27, 2025, amendments to the SEBI (Debenture Trustees) Regulations, 1993 were notified, whereby regulation 9C was incorporated, to bring clarity on the permitted activities for Debenture Trustees (DTs). Vide this circular, the conditions for Debenture Trustees to undertake activities that are not regulated by SEBI are prescribed. Further provided that a DT which is also regulated by the Reserve Bank of India, shall carry out the activity of DT through Separate Business Unit of such DT. Therefore, the terms and conditions as specified shall be complied with by such SBU.
Caution to Public regarding unregistered Online Bond Platform Providers
SEBI has enabled investments in gold and gold related instruments through various SEBI regulated gold products. These are exchange traded commodity derivative contracts, Gold Exchange Traded Funds (ETFs) offered by Mutual Funds and Electronic Gold Receipts (EGRs) tradeable on stock exchanges. It has come to the notice of SEBI that some digital/online platforms are offering investors to invest in ‘Digital Gold/E-Gold Products’. Digital Gold is being marketed as an alternative for investment in physical gold. In this context, it is informed that such digital gold products are different from SEBI regulated gold products as they are neither notified as securities nor regulated as commodity derivatives. They operate entirely outside the purview of SEBI. Such digital gold products may entail significant risks for investors and may expose investors to counterparty and operational risks.
SEBI eyes index inclusion for REITs to boost liquidity, investor participation, says Chairman Tuhin Kanta Pandey
SEBI Chairman Tuhin Kanta Pandey on Friday, 21 November, 2025 said the markets regulator is actively examining the inclusion of REITs (Real Estate Investment Trusts) in market indices through a calibrated glide path – a move that could materially improve liquidity, visibility, and institutional participation in these instruments. The proposed index entry marks the most significant policy signal yet for India’s nascent REIT market, which the regulator believes must play a far larger role in funding the country’s long-term infrastructure needs. Speaking at an event in New Delhi, Chairman said that enhancing market access and liquidity for REITs and InvITs (Infrastructure Investment Trusts) is now a priority. India is already the fourth-largest REIT market in Asia, but depth remains limited: retail penetration is just 1 percent, and domestic REITs and InvITs still lack sufficient liquidity.
Reserve Bank Of India
Indian Banks Far More Mature Than a Decade Ago: RBI Governor
- Governor of RBI Sanjay Malhotra, said that Indian banks are far more mature compared to a decade ago. Addressing the State Bank of India Banking and Economics Conclave 2025 in Mumbai, the Governor, noted that the State Bank of India has transformed from being in loss in 2018 to becoming a 100 billion dollar company. The RBI Governor highlighted a series of regulatory measures-including the Asset Quality Review (AQR) in 2015, the Prompt Corrective Action (PCA) Framework, consolidation of 27 public sector banks, massive recapitalisation, and the Insolvency and Bankruptcy Code (IBC)-which have fundamentally transformed India’s credit culture. He also noted that, in parallel, major reforms were undertaken to strengthen monetary and macroeconomic stability. These included the adoption of a flexible inflation-targeting regime, deepening of forex markets, and the gradual liberalisation of the capital account.
Source: https://www.newsonair.gov.in/indian-banks-far-more-mature-than-a-decade-ago-rbi-governor/
Income Tax And Goods And Services Tax
GST Revenue Soars in October 2025
Gross Goods and Services Tax (GST) revenue collected for October 2025 is ₹1,95,936 crores, registering a 4.6% increase compared to ₹1,87,346 crores for the same month last year. The sharp rise in GST collections in the onset of the recent GST rate rationalisation in late September 2025 indicates sustained consumer demand during the festive season. The yearly growth for October 2024 to October 2025 is captured at 7.8% rising from ₹9,65,138 crores in October 2024 to ₹10,40,055 crores in October 2025. The monthly Gross Domestic revenue is 2% higher from ₹1,42,251 crores in October 2024 to ₹1,45,052 in October 2025, while Gross GST Revenue from imports registered a yearly growth of 12.9%, reflecting strong trade activity.Source:https://www.pib.gov.in/FactsheetDetails.aspx?id=150446&NoteId=150446&ModuleId=16
Digital Personal Data Protection (DPDP) Rules, 2025
The Government of India notified the Digital Personal Data Protection (DPDP) Rules, 2025 on 14 November 2025. This marks the full operationalisation of the Digital Personal Data Protection Act, 2023 (DPDP Act). Together, the Act and the Rules form a clear and citizen-centred framework for the responsible use of digital personal data. They place equal weight on individual rights and lawful data processing.
The Digital Personal Data Protection Act and the DPDP Rules mark an important step in building a trustworthy and future-ready digital environment for the country. They bring clarity to how personal data must be handled, strengthen the rights of individuals and create firm responsibilities for organisations. The framework is practical in design and backed by wide public consultation, which makes it both inclusive and responsive to real needs. It supports the growth of India’s digital economy while ensuring that privacy remains central to its progress. With these measures now in place, India moves towards a safer, more transparent and innovation-friendly data ecosystem that serves citizens and strengthens public confidence in digital governance.
Source: https://static.pib.gov.in/WriteReadData/specificdocs/documents/2025/nov/doc20251117695301.pdf
LABOUR CODES
In a historic decision, the Government of India has announced that the four Labour Codes – 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 are being made effective from 21st November 2025, rationalising 29 existing labour laws. By modernising labour regulations, enhancing workers’ welfare and aligning the labour ecosystem with the evolving world of work, this landmark move lays the foundation for a future-ready workforce and stronger, resilient industries driving labour reforms for Aatmanirbhar Bharat.
Many of India’s labour laws were framed in the pre-Independence and early post-Independence era (1930s–1950s), at a time when the economy and world of work were fundamentally different. The new codes empower both workers and enterprises, building a workforce that is protected, productive and aligned with the evolving world of work, paving the way for a more resilient, competitive and self-reliant nation.
Source: https://www.pib.gov.in/PressReleseDetailm.aspx?PRID=2192463®=3&lang=2
Insolvency And Bankruptcy Board Of India
Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) (Second Amendment) Regulations, 2025
20th November, 2025
The Insolvency and Bankruptcy Board of India (IBBI) issued a Notification to further amend the Insolvency and Bankruptcy Board of India (Insolvency Resolution Process for Personal Guarantors to Corporate Debtors) Regulations, 2019. It came into force on the date of their publication in the Gazette of India.
The amendment inserts a new Regulation 23, titled “Filing of Forms,” after the existing Regulation 22 in the principal regulations. This new regulation imposes specific duties and consequences related to the filing of forms by the Resolution Professional (RP) during the Insolvency Resolution Process for Personal Guarantors to Corporate Debtors.
https://ibbi.gov.in/uploads/legalframwork/9cfc3f68f2b3726291d4713b0222205a.pdf
Insolvency and Bankruptcy Board of India (Insolvency Professionals) (Second Amendment) Regulations, 2025
20th November, 2025
The Insolvency and Bankruptcy Board of India (IBBI) issued a Notification to further amend the Insolvency and Bankruptcy Board of India (Insolvency Professionals) Regulations, 2016. It came into force on the date of their publication in the Gazette of India.
A new regulation, Regulation 7B: “Number of Assignments,” has been inserted, placing a cap on the number of cases an individual insolvency professional (one who is not an Insolvency Professional Entity) can handle.
As per the inserted regulation 7B, an insolvency professional (IP) who is not an insolvency professional entity, shall not at any point of time, have more than ten (10) assignments in aggregate as interim resolution professional and resolution professional in a corporate insolvency resolution process and as a liquidator in a liquidation process, of which not more than three (3) assignments shall have admitted claims exceeding one thousand (1000) crore rupees each.
IPs already exceeding the limit on the commencement date cannot accept new assignments until their ongoing assignments fall within the permissible cap.
The amendment also revises the Code of Conduct of IPs given under regulation by Replacing “approval of the Board” with “prior approval of the Adjudicating Authority” in clause 6 of the code of conduct and clarification under clause 22 was removed due to insertion of the new regulation- Regulation 7B.
https://ibbi.gov.in/uploads/legalframwork/028a7d566c32d5e2649744e6e99179df.pdf
IBBI Circular – Strengthening due diligence under Section 29A- reg.
Circular No. IBBI/CIRP/88/2025 dated 18th November, 2025
The Insolvency and Bankruptcy Board of India (IBBI) issued a Circular (No. IBBI/CIRP/88/2025) on November 18th, 2025, to strengthen the due diligence process under Section 29A of the IBC.
As per the circular Resolution Professionals (RPs) are now directed to present a detailed note on Section 29A compliance to the Committee of Creditors (CoC) when resolution plans are being considered. Furthermore, the RP must ensure that all CoC deliberations and observations regarding eligibility are properly recorded in the minutes.
https://ibbi.gov.in/uploads/whatsnew/ae3618a064edb62e15dc7a7a038b6deb.pdf
IBBI Circular -Undertaking by IPs before Special Courts under PMLA
Circular No. IBBI/CIRP/87/2025 dated 4th November, 2025
The Insolvency and Bankruptcy Board of India (IBBI) has issued a circular requiring Insolvency Professionals (IPs) to furnish a standardised undertaking before the Special Court under the Prevention of Money Laundering Act (PMLA) when seeking restitution of assets attached by the Enforcement Directorate (ED).
In many CIRP and liquidation cases, assets of the Corporate Debtor are attached by the ED under PMLA. Restitution of such assets can significantly increase value and realisation. IPs are encouraged to file applications under Sections 8(7) or 8(8) of PMLA before the Special Court for release of such attached assets.To streamline the process, a standard undertaking has been developed by IBBI in consultation with ED, which IPs must file along with their restitution applications.
The undertaking ensures proper use of restituted assets, quarterly reporting, full disclosures, and cooperation with ED. It aims to speed up Special Court proceedings and improve value realisation in CIRP and liquidation cases.
https://ibbi.gov.in/uploads/legalframwork/f6d5c57a6d01859a965249aae941b9fd.pdf
IBBI Discussion Papers
Template for declaration of Beneficial Ownership and Section 32A Affidavit to be submitted by Prospective Resolution Applicant (PRA) – 6th November, 2025
https://ibbi.gov.in/uploads/whatsnew/e22f299cdc9290dec85eb355501873ca.pdf
Strengthening the Valuation Process under the IBC – 14th November, 2025
https://ibbi.gov.in/uploads/whatsnew/07994904562b27286b00c4def2cc79a0.pdf
Proposed Guidelines for Conducting Valuation under the Insolvency and Bankruptcy Code, 2016. – 19th November, 2025
https://ibbi.gov.in/uploads/whatsnew/97388870e87e11d5df09b29b69bbbb38.pdf
Empowering Directors/Partners in Insolvency Professional Entities (IPEs) by proposing Minimum Shareholding/ Capital Contribution – 17th November 2025
https://ibbi.gov.in/uploads/whatsnew/78e2d0552e336e62ecd7d8e827454f1f.pdf
Strengthening safeguards and transparency in the CIRP – 17th November 2025
https://ibbi.gov.in/uploads/whatsnew/a7bfbe7ab72d0416cca0031427f7b0f8.pdf
Disclaimer: This Newsletter is designed to provide information of corporate and legal updates during the particular period and is not intended as a substitute for professional consultation and advice in a particular matter. We request to read or refer to the relevant law, rule or notification before concluding or taking any decision of the contents. In no event we are not be liable for any damages whatsoever arising out of the use of or reliance on the contents of this newsletter. This Newsletter is for private circulation purpose only.
Disclaimer: This newsletter is prepared by G.V. and Associates, Company Secretaries & Advisory Solutionz (P) Ltd. for knowledge sharing and compliance awareness. It does not constitute legal opinion or formal advisory.