1. What is Form DPT-3?
Form DPT-3 is a return filed with the ROC to report:
- Return of Deposit.
- Particulars of transactions by a company not considered as a deposit as per rule 2(1)(c) of the Companies (Acceptance of Deposit) Rules, 2014.
- Return of Deposit and particulars of transactions by a company not considered as deposit.
- One-time Return for disclosure of details of outstanding money or loan received by a company but not considered as deposits in terms of rule 2(1)(c) of the Companies (Acceptance of Deposits) Rules, 2014.
2. Who is required to file DPT-3?
Applicable to all companies except:
- Government Companies
- Banking Companies
- NBFCs registered with RBI
- Housing Finance Companies registered with NHB.
3. What is the due date for the annual DPT-3 filing?
On or before 30th June every year for information outstanding as on 31st March.
4. Is DPT-3 applicable to Private Companies?
Yes. Private Companies are required to file DPT-3 if they have outstanding loans/money not treated as deposits.
5. Is DPT-3 applicable even if the company has only Director’s Loan?
Yes. Director’s loan is exempt from the definition of deposit but is reportable in DPT-3 if outstanding as on 31 March.
6. Is DPT-3 applicable for Share Application Money?
If share application money is outstanding as on 31 March and falling under the exempted categories, it should be reported.
Example: The Company received share application money on 25th March and completed the share allotment 15th April, i.e. within allotment completed within 60 days of receipt of Share Application Money, then such receipt of Share Application Money is exempted from the Deposits; however, it shall be reported in Form DPT-3 as Exempted Deposits.
7. Is DPT-3 applicable for Inter-Corporate Loans?
Yes. Loans received by one Company from another company are exempt deposits but are reportable in DPT-3.
8. Is DPT-3 applicable for Security Deposits from Customers?
Yes, if outstanding and covered under Rule 2(1)(c) exemptions.
9. Is DPT-3 applicable for Advance from Customers?
Yes, advances from customer outstanding as on 31 March should be evaluated and reported under the relevant category.
(a) For an outstanding amount to be considered as Exempted Deposits, any money received as an advance for the supply of goods or provision of services shall be appropriated against the supply of goods or provision of services within a period of three hundred and sixty-five days from the date of acceptance of such advance.
Example: Advance is received from the Customer on 1st January 2026, and the entire advance amount is appropriated against the supply of goods on 30th June 2026, then such amount will be treated as an exempted deposit; however, since the Advance was outstanding as on 31st March 2026, and 365 days had not expired, it shall be reported in Form DPT-3 as Exempted Deposits.
If any money received as an advance for the supply of goods or provision of services is not appropriated against the supply of goods or provision of services within a period of three hundred and sixty-five days from the date of acceptance of such advance and the same is still outstanding, then it will be treated as a deposit.
Example: Advance is received from the Customer on 1st April 2025, and the entire advance amount is appropriated against the supply of goods on 30th June 2026, then such amount will be treated as a deposit, because the amount is not appropriated within 365 days.
10. If all loans are repaid before 31 March, is DPT-3 required?
No. DPT-3 reports outstanding amounts as on 31 March. If nothing is outstanding, generally filing is not required.
However, if loans are taken during the financial year and the same is repaid also during the same financial year, then it is advisable to file Form DPT-3. Since the new version of the Form DPT-3 has a column for reporting of the following:
– Opening Balance
– Additional loan during the year
– Repaid during the year
– Any other adjustment
– closing balance
Hence, it is advisable to file Form DPT-3 if a loan is taken during the year and the same is repaid also in the same financial year.
11. Is Nil DPT-3 required?
The commonly accepted view is that if there is no outstanding deposit or exempted deposit as on 31 March, DPT-3 is not required.
If there is no opening balance, there is no additional loan taken, there is no repayment of existing outstanding loan, there is no other adjustment or there is not transactions related to loans and there is no closing balance or outstanding, then Form DPT- is not required to be filed.
12. Is DPT-3 applicable to Section 8 Companies?
Yes. Since Section 8 Companies are not specifically exempted, and if they have any transactions that fall under exempted deposits, then they are also required to file Form DPT-3.
13. Is DPT-3 applicable to OPCs?
Yes. OPCs are also covered if they have outstanding reportable amounts.
14. Is the Auditor’s Certificate mandatory?
Mandatory only when filing a “Return of Deposit”. For reporting exempted deposits, it is generally not mandatory.
15. Is Professional Certification mandatory?
No. DPT-3 does not require certification by a Practicing CS/CA/CMA.
16. Is DPT-3 an STP Form?
No. ROC processes it and is not an STP form.
17. Are Loans from Shareholders Reportable?
Yes, if outstanding and covered under the exempted categories.
18. Are Foreign Loans Reportable?
Yes. ECBs and other foreign borrowings exempted under Rule 2(1)(c) are generally reportable if outstanding.
19. Are Outstanding Expenses Reportable?
Generally, No. Trade creditors, salary payable, professional fees payable, director remuneration payable etc., are not “receipts of money” and therefore not reportable.
20. Are NBFC Loans Reportable?
Yes. Loans from NBFCs are reportable under loans received from body corporates/companies.
21. Are Unsecured NCDs Reportable?
Yes. Depending upon their nature and exemption, NCDs may be reportable in DPT-3.
22. Whether a loan from a shareholder of a Private Company is an exempted deposit or a deposit?
This is one of the most debated questions.
- Loan from shareholder is not covered under Rule 2(1)(c)(viii) (which covers directors).
- It may be accepted by a private company, subject to exemption notifications and conditions.
23. If a person is both Director and Shareholder, under which category should the loan be reported?
The determining factor is whether the company has complied with the conditions applicable to loans from directors and obtained the prescribed declaration.
If director-loan conditions are satisfied, it can be disclosed as “Particulars not considered as deposit”.
24. Can a Private Company accept a loan from a relative of a shareholder?
If such a relative is neither a Shareholder nor a relative of a Shareholder Director, then any amount received from such relative will be treated as Deposits.
25. Can a Private Company accept a loan from an HUF of a shareholder?
If HUF is not a Shareholder, then it will be treated as Deposits even if that HUF belongs to a Shareholder.
26. Can a Private Company accept a loan from an HUF of a Director?
Yes, since HUF falls under the definition of Relatives and since a Private Company is allowed to take a loan from Relatives of Directors, it will fall under the exempted Deposits.
27. Whether warrant application money is reportable?
Yes, A very practical issue in listed companies and startups. If outstanding as on 31 March, it should be evaluated for DPT-3 disclosure.
28. Whether CCDs are Loans or Capital Receipts for DPT-3?
The Company received application money from the individual and allotted CCD, even though CCDs are compulsorily convertible into Equity Shares, and there is no repayment obligation, and they have the substance of Equity. However, such CCD will be reflected as Borrowing until they are converted into Equity. Hence, it is advisable to report in DPT-3 under “Particulars not considered as Deposit” to avoid under-reporting.
29. Whether Convertible Notes issued by Startups are Reportable?
Convertible Notes issued by Startups are initially treated as Debt until they are converted into Equity; hence, they shall be reported in DPT-3 under “Particulars not considered as Deposit” to avoid under-reporting.
