Apply the 2026 framework
MCA announced that the amendment effective 31 March 2026 replaces annual KYC with an intimation every three years. Its January 2026 release identifies 30 June 2028 as the next filing date for directors who had already completed KYC covered by that announcement.
Do not extend that example to every newly allotted DIN or unresolved historical default. Establish the applicable cycle from the holder’s facts and the current rule and portal instructions. An old checklist requiring everyone to file each September is no longer an adequate basis.
Identify the filing purpose
The revised process distinguishes periodic KYC, changes to mobile number, email or residential address, and DIN reactivation. MCA’s announcement states that digital-signature verification by the holder and professional certification apply when those contact or address details are updated.
Record what has changed and the effective date. Do not wait for a periodic reminder to investigate a details-update requirement, and do not assume a contact update automatically resets the periodic cycle.
Prepare the holder record
- DIN and its current portal status.
- DIN allotment date and prior KYC acknowledgements.
- Current identity and address evidence relevant to the filing.
- Personal mobile number and email access for the authorised verification process.
- Details of changes since the last confirmed record.
- Applicable signing and certification arrangements.
- Open portal queries or prior unsuccessful submissions.
Keep control of verification
The holder should review the particulars before confirming them. Coordinate the filing without handing over long-term control of personal email, mobile accounts or digital-signature credentials. Keep identity documents in a controlled workspace.
For example, a former adviser’s email address in an old working sheet should not be copied into a fresh confirmation as though it were the holder’s current personal contact. Resolve the underlying record and use the appropriate update process.
Address inactive DIN status
Read the actual status and reason shown by MCA. A KYC-related issue, disqualification and another administrative status are not interchangeable. Identify the applicable correction or reactivation procedure from that reason.
Preserve past filings and payment evidence while resolving discrepancies. Do not assume that resigning from one company removes all obligations associated with holding a DIN.
Save completion evidence
Retain the submitted particulars, acknowledgement, payment evidence where relevant and confirmed portal outcome. Update the internal calendar with the applicable next action and the basis used to calculate it.
A draft or payment reference alone should not be marked as completed KYC. Check the final status and keep unresolved errors assigned to an owner. Kosha.Services can help organise the history and filing checklist using the holder’s actual DIN and change records.
References and official procedures
- MCA via PIB: three-year KYC framework effective 31 March 2026
- MCA: current filing services and instructions
Source material consulted 1 October 2026. Check the applicable instrument, period and portal instructions for the actual assignment.
Kosha.Services · Updated 2 October 2026
