DIR-3 KYC for Directors: Now Once Every Three Years

Every individual who holds a Director Identification Number (DIN) must periodically confirm his or her identity and contact details to the Ministry of Corporate Affairs through DIR-3 KYC. Until recently this was an annual filing. Under the amended Companies (Appointment and Qualification of Directors) Rules, 2014, the KYC is now filed once every three financial years, by 30 September.

This article explains who must file, what changed, and what happens if the KYC is missed.

Who must file

• Every individual who has been allotted a DIN, whether or not the person is currently a director of any company
• Including directors of private, public and one person companies, and designated partners of LLPs who hold a DIN
• Including persons whose DIN was allotted but who have not yet been appointed anywhere

A person who no longer needs the DIN can apply for its surrender instead of filing KYC, provided the person is not a director of any company.

What changed

Point	Earlier position	Current position
Frequency	Every financial year	Once every three financial years
Due date	30 September every year	30 September of the year in which it falls due
Change in mobile number, email or address	Reflected at the next annual KYC	Updated separately when the change occurs, within the time allowed by the rules

The change reduces the routine filing burden, but makes it more important to update contact details promptly, since the MCA relies on the registered mobile number and email for verification.

Filing the KYC

1. Keep the director’s PAN, Aadhaar or passport, and current address proof ready.
2. The personal mobile number and email of the director are verified by one-time passwords; they should belong to the director, not to the company or the professional filing the form.
3. The director signs with a valid digital signature.
4. Where the form requires it, it is certified by a practising professional.
5. File on the MCA portal and keep the acknowledgement.

Consequences of not filing

• The DIN is marked deactivated on the MCA portal.
• Filings that need that director’s DIN cannot be made, which can hold up company filings.
• The DIN is reactivated only on filing the KYC with the late fee of ₹5,000.

Deactivation of DIN for non-filing of KYC is different from disqualification of a director under Section 164 for a company’s continued non-filing of financial statements or annual returns. See replies to MCA notices.

Annual compliance for the company itself is summarised in the annual compliance calendar.

Frequently asked questions

If I filed KYC last year, when is the next one due?

The next filing falls due in the year notified under the three-year cycle. The status shown against the DIN on the MCA portal should be checked.

Is KYC needed if I am not a director of any company now?

Yes, as long as the DIN is active. If it is no longer needed, surrender of the DIN can be considered.

Can the company’s email be used?

No. The mobile number and email must be the director’s own, since they are used to verify the director personally.

ചുരുക്കം (Summary in Malayalam)

DIN ഉള്ള എല്ലാ വ്യക്തികളും DIR-3 KYC ഫയൽ ചെയ്യണം. മുമ്പ് ഇത് എല്ലാ വർഷവും ഫയൽ ചെയ്യണമായിരുന്നു; ഇപ്പോൾ മൂന്ന് സാമ്പത്തിക വർഷത്തിൽ ഒരിക്കൽ, സെപ്റ്റംബർ 30-നകം. മൊബൈൽ നമ്പർ, ഇമെയിൽ, വിലാസം എന്നിവ മാറുമ്പോൾ പ്രത്യേകം അപ്ഡേറ്റ് ചെയ്യണം. ഡയറക്ടറുടെ സ്വന്തം മൊബൈലും ഇമെയിലും OTP വഴി പരിശോധിക്കും. ഫയൽ ചെയ്തില്ലെങ്കിൽ DIN ഡിആക്ടിവേറ്റ് ആകും; ₹5,000 ലേറ്റ് ഫീസോടെ ഫയൽ ചെയ്താൽ മാത്രമേ വീണ്ടും ആക്ടീവ് ആകൂ.

This article gives a general overview of DIR-3 KYC under the Companies (Appointment and Qualification of Directors) Rules, 2014. The rules, forms and due dates have been revised and may be revised again; for accurate and current requirements, refer to the rules as amended and the MCA portal. The article is not advice on any particular case.