If you hold a Director Identification Number, DIN KYC filing is not optional. It is an annual compliance mandate from the Ministry of Corporate Affairs (MCA) that every DIN holder must fulfil, regardless of whether the company is active, dormant, or even struck off. Failing to file your DIR-3 KYC form on time results in immediate deactivation of your DIN, a penalty of Rs. 5,000, and the inability to sign or file any document with the MCA until the issue is resolved.
Introduced in 2018 under Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014, the annual DIN KYC filing was designed to keep the government's director database accurate and verified. Think of it as an annual identity refresh. The MCA wants to confirm that the person behind every DIN is reachable, verifiable, and still the same individual on record.
This guide covers everything you need to know about the DIR 3 KYC form filing process, the due date, documents required, fees, the difference between the e-form and web-based options, and what to do if your DIN has already been deactivated.
What is DIN KYC and Why is it Mandatory?
DIN KYC is the annual Know Your Customer verification that every director must complete with the MCA. The purpose is straightforward. The government wants to maintain an updated register of directors with their current personal details, contact information, and identity proof. Before this requirement existed, many DIN holders had outdated phone numbers, email addresses, or even incorrect residential details on file.
The legal basis for this compliance lies in Rule 12A of the Companies (Appointment and Qualification of Directors) Rules, 2014. According to this rule, every individual who has been allotted a DIN as of 31st March of a financial year must submit their KYC details to the MCA by 30th September of the immediately following financial year. This applies universally. Whether you are an active director in multiple companies, a designated partner in an LLP holding a DIN, a disqualified director, or someone who resigned years ago but never surrendered the DIN, you are still required to complete DIN KYC filing every year.
The rationale is simple. A DIN is a lifetime number. Once allotted, it stays with you unless voluntarily surrendered. And as long as it exists in the MCA system, the government needs current and verified data linked to it.
Who Needs to File DIR-3 KYC?
The scope of this filing is wider than most directors realize. Here is a clear breakdown of who must file:
- Every individual holding a DIN in 'Approved' status as on 31st March of the relevant financial year.
- Directors of active, dormant, or struck-off companies. The company's status does not exempt the director from KYC.
- Disqualified directors under Section 164(2) of the Companies Act, 2013. Disqualification does not remove the DIN.
- Foreign nationals holding a DIN for directorship in Indian companies.
- Directors who have resigned from all companies but have not surrendered their DIN.
- Designated partners of LLPs who were allotted a DIN (though LLP partners typically use DPIN, some hold a DIN from prior company associations).
In essence, if you have a DIN, you must file. There are no exceptions based on turnover, company type, or directorship status.
DIR-3 KYC e-Form vs DIR-3 KYC Web Service
The MCA provides two distinct methods for completing your DIN KYC filing. Choosing the right one depends on whether you are filing for the first time or simply confirming previously submitted details.
| Parameter | e-Form DIR-3 KYC | DIR-3 KYC Web Service |
| When to use | First-time filing or updating details | No changes to previously filed details |
| DSC required | Yes, mandatory | No |
| Professional certification | Yes (CA, CS, or CMA) | Not required |
| Document upload | Yes (ID and address proof) | Not required |
| OTP verification | Yes (email and mobile) | Yes (email and mobile) |
| Fee (within due date) | Nil | Nil |
| Fee (after due date) | Rs. 5,000 | Rs. 5,000 |
If your personal details such as address, email, mobile number, or nationality have changed since your last filing, you must use the e-Form. The web service is only for directors whose details remain unchanged and who have previously completed at least one full DIR-3 KYC e-form filing.
Step-by-Step Procedure for DIN KYC Filing
Step 1: Check Your DIN Status
Before starting the filing, visit the MCA portal and check the current status of your DIN. Navigate to the 'Check DIN Status' section on the MCA website. Enter your DIN and verify whether the status shows 'Approved' or 'Deactivated due to non-filing of DIR-3 KYC.' This determines whether you file without a fee or with the Rs. 5,000 penalty.
Step 2: Obtain or Renew Your Digital Signature Certificate
If you are filing the e-Form DIR-3 KYC (first-time filers or those updating details), a valid DSC is mandatory. The DSC must be registered with the MCA portal and linked to your DIN. If your existing DSC has expired, get it renewed from any licensed Certifying Authority before proceeding.
Step 3: Download and Fill the DIR-3 KYC Form
Download the latest version of the DIR-3 KYC e-form from the MCA portal. Fill in your personal details including full name, father's name, date of birth, nationality, residential address, permanent address, email ID, and mobile number. Ensure every field matches your identity documents exactly. Even minor discrepancies in spelling or address format can cause rejection.
Step 4: Attach Supporting Documents
Upload scanned copies of your identity proof and address proof. For Indian nationals, Aadhaar and PAN are typically required. Foreign nationals must attach a valid passport. All documents should be attested by a practicing CA, CS, or Cost Accountant. The professional attestation is a mandatory requirement for the e-form.
Step 5: Verify via OTP
The MCA sends OTPs to the mobile number and email address you have entered in the form. Both OTPs must be verified successfully before the form can be submitted. This dual verification ensures that the contact details on file are genuine and accessible to the director.
Step 6: Affix DSC and Submit
After OTP verification, attach your DSC to the form. The practicing professional who certified the form must also affix their DSC. Once both signatures are in place, upload and submit the form on the MCA portal. You will receive an SRN (Service Request Number) as confirmation of successful submission.
Documents Required for DIR-3 KYC Form Filing
Keeping your documents ready before starting the filing process saves time and avoids last-minute issues. Here is the complete list:
- PAN card (mandatory for Indian nationals)
- Aadhaar card
- Passport (mandatory for foreign nationals, optional for Indian directors)
- Voter ID or driving licence (as additional address proof, if required)
- Latest utility bill, bank statement, or telephone bill as proof of current residential address (not older than two months)
- Valid Digital Signature Certificate (DSC) linked to the MCA portal
- Professional attestation by a practicing CA, CS, or Cost Accountant
For the DIR-3 KYC web service, no document upload is needed. You simply verify your existing details via OTP. However, the web service is only available if you have already filed the full e-form at least once.
Due Date, Penalty, and DIN Reactivation
The due date for DIN KYC filing is 30th September of every year. For example, for the financial year ending 31st March 2025, the DIR-3 KYC must be filed by 30th September 2025. This deadline applies uniformly to all DIN holders, with no extensions typically granted.
If you miss the deadline, the consequences are immediate. The MCA system automatically marks your DIN as 'Deactivated due to non-filing of DIR-3 KYC' on 1st October. Once deactivated, you cannot sign any MCA form, file any return, or act as a director in any official capacity until the DIN is reactivated.
To reactivate your DIN, you must file the DIR-3 KYC e-form (not the web service) and pay a penalty of Rs. 5,000. The reactivation happens after the form is processed and approved by the MCA, which typically takes 2 to 5 working days. During this period, any annual compliance filings that require the director's DSC will remain on hold.
Common Mistakes to Avoid During DIN KYC Filing
Even though the process appears simple, directors frequently encounter issues due to avoidable errors. Here are the most common ones:
- Using the web service when details have changed: If you have moved to a new address or changed your phone number, you must use the e-form. The web service only confirms existing details and does not allow updates.
- Expired or unlinked DSC: An expired DSC or one that is not registered on the MCA portal will prevent form submission. Always verify your DSC validity before the filing window opens.
- Mismatch between form data and documents: If the address on your Aadhaar does not match the address entered in the form, the MCA may reject the filing. Ensure consistency across all documents.
- Not verifying OTPs promptly: OTPs have a limited validity period. If you delay verification, the OTPs expire, and you need to restart the process.
- Assuming dormant companies exempt directors from KYC: Your company's status has no bearing on your KYC obligation. Even if the company is dormant, struck off, or under liquidation, your DIN still requires annual KYC.
Working with a qualified professional, such as a Chartered Accountant or Company Secretary, helps you avoid these pitfalls and ensures your filing is accepted without complications.
Conclusion
DIN KYC filing is one of the simplest yet most frequently overlooked annual compliance requirements for company directors in India. Missing the 30th September deadline leads to automatic DIN deactivation, a Rs. 5,000 penalty, and disruption to your ability to sign and file critical company documents. Whether you use the e-form or the web service, the process takes very little time when done correctly.
If you are a director in one company or several, managing your DIN KYC should be part of your annual compliance calendar. For professional assistance with DIR 3 KYC form filing, DIN reactivation, DSC procurement, or any other director-related compliance, reach out to the team at Patron Accounting. Their experienced CAs and Company Secretaries handle the entire process efficiently, so you stay compliant without the hassle.
