Many companies are taking the view that the last date for filing their Annual Return with the MCA is 30th Nov, 2011. Then they back calculate and say it will take 15 days for the vendor to create an xbrl document. They think they can get up on 12th November, and be compliant!

I wish to demolish the myth that they need to wake up on 15th November!

Let us see the whole process:                                                                 days

You call the vendor, he quotes a figure for converting :                 2

Your board asks for 2-3 comparative quotes                    :                 2

Your company accepts one vendor                                                          1

Client asks for pdf and other details                                                          2

You send all the details                                                                                  2

Vendor starts and completes  work                                                       14

Auditor does a review                                                                                   4

Vendor does some regrouping                                                                 2

Auditor certifies                                                                                             1

the whole process ASSUMING no snags takes about 30 days. Can we assume that the MCA website will be overloaded from 15th November onwards?

Sure.

What happens if the Validator does NOT ACCEPT the filing?

Well, you go back to the vendor and say …please do it again.

What happens if he CANNOT?

Well you look for a NEW vendor.

Is this a real threat?

Well a vendor who has never got his work validated by a 3rd party will not know the significance of a validation process…so yes the risk is real.

Will a responsible vendor accept work WITH A DEADLINE after 1st of November?

I doubt it. He would be hard-pressed to do his own work – either he will refuse work or charge you double the fees.

Will you be able to file it without paying a fine?

No.

So you will end up paying a fine.

Is the fine too high?

Well it is not the amount, but the fact that in many companies the BOARD insists that all fines and penalties be brought to the attention of the Board. I remember putting a statement in my Internal Audit report of a manufacturing company  a statement saying ‘The company has not paid any extra fee or penalty for any kind of non compliance or delay’. Obviously the Board was seeing that statement in every MONTHLY board meeting.

So do you want to wake up on 15th September or 15th November is your call. Do what works for you!