ROC and secretarial compliance
DPT-3 Classification Checklist for Private Companies
A books-to-DPT-3 classification workflow for private companies covering deposits, amounts not treated as deposits, combined reporting, entity scope, audit evidence, and unresolved items.
12 min read
Short answer
Do not decide DPT-3 from a ledger called 'loan' or assume every company and borrowing must be reported. Start with entity scope, then review every outstanding receipt of money against section 2(31) of the Companies Act and the exact Rule 2(1)(c) limb and conditions. Reconcile opening balance, additions, repayments, adjustments, closing balance, counterparty, source, purpose, agreement, approvals, bank trail, financial-statement treatment, and auditor evidence. Rule 16 governs the annual return of deposits; Rule 16A introduced a fixed historical one-time return for specified outstanding money or loans not treated as deposits. The current DPT-3 form notified in 2022 also displays deposit, non-deposit, combined, and one-time purposes. Select a current purpose only after the rules, form, company type, transaction facts, and live MCA process agree.
One balance sheet can contain several different rule outcomes
The finance owner splits the balance by receipt date and counterparty before applying a rule. The director amount needs the status-at-receipt and prescribed declaration evidence. The relative route has conditions specific to a private company and cannot be borrowed from the director line. An amount from another company sits under a different Rule 2(1)(c) limb. A customer advance depends on the underlying supply, contract, use, age, refund position, dispute, and the rule's conditions. Some lines may be amounts not treated as deposits; another may remain unresolved or be a deposit. The example does not decide any line.
Check entity and return scope before transaction detail
| Scope fact | Authority to check | Decision control |
|---|---|---|
| Company or another entity form | Companies Act status and incorporation record | Do not apply a Companies Act webform to an LLP, partnership, proprietorship, or individual merely because the books contain a loan. |
| Banking, NBFC, or other specified status | Section 73 carve-outs, current Rule 1 scope, regulator registration, and notifications | Do not say all companies file. Verify whether the Chapter or Rules exclude or separately regulate the entity. |
| Government company | Company ownership/control facts, current Rule 16 and MCA form instructions | The current MCA kit frames annual DPT-3 filing for a company other than a government company. Confirm the live form and applicable rule rather than inferring from a private/public label. |
| Deposit accepted or outstanding | Sections 73/76, Rules, agreements, circulars, approvals, repayment terms | Deposit compliance carries conditions beyond choosing a DPT-3 purpose and needs specialist review. |
| Outstanding receipt not treated as deposit | Exact Rule 2(1)(c) limb, every condition, Rule 16A history, 2022 form purpose | Record why the amount falls within a stated limb; do not label every exempt or excluded amount an annual filing automatically. |
| No outstanding receipt at the review date | Opening, receipts, repayments, adjustments, closing ledger and prior return | Test the current rule and live form for the company's facts; do not promise that a nil filing is required or unnecessary without authority. |
Direct answer
A private-company title narrows the intended reader; it does not eliminate the entity-scope gate. The reviewer still verifies the company's legal and regulatory status before classifying transactions or selecting a form purpose.
Separate the annual return from the historical one-time purpose
| Purpose or rule | What the official material says | Safe use now |
|---|---|---|
| Rule 16 annual return of deposits | A company covered by the rule files the prescribed return with information as at 31 March, duly audited; the 2022 amendment added an auditor declaration in DPT-3. | Use for an annual deposit-return analysis only after entity scope and deposit facts are confirmed. |
| Rule 16A(3) one-time return | The rule and G.S.R. 341(E) fixed a historical window for outstanding receipts from 1 April 2014 to 31 March 2019 not treated as deposits, with a one-time period measured from 31 March 2019. | Treat it as a historical one-time purpose, not a recurring annual instruction for current non-deposit balances. |
| 2022 form: return of deposits | G.S.R. 663(E) includes a deposit-return purpose and deposit schedules. | Tie the selection to Rule 16, audited figures, and deposit evidence. |
| 2022 form: particulars not considered deposits | The notified form includes a purpose for transactions not treated as deposits under Rule 2(1)(c). | Reconcile this current form choice with Rules 16/16A and current MCA instructions; obtain professional review rather than relying on the label alone. |
| 2022 form: combined return | The notified form includes a combined deposit and non-deposit transaction purpose. | Use only when both populations, authority, audited totals, and schedules are supportable. |
| 2022 form: one-time disclosure | The form retains a one-time purpose for the historical outstanding-money or loan disclosure. | Do not use it as a current annual catch-all or reset its closed historical dates. |
Classify each receipt under the exact Rule 2(1)(c) limb
| Receipt family | Facts and evidence to test | Common unsafe shortcut |
|---|---|---|
| Government, statutory, foreign, bank, or financial-institution source | Counterparty legal status, governing approval, guarantee or facility terms, FEMA or regulator facts where relevant, receipt and outstanding balance | Treat every institutional-looking lender as automatically outside deposit rules. |
| Amount from another company | Lender incorporation status, agreement, Board authority, bank trail, opening/addition/repayment balance, related-party and financial-statement treatment | Classify a group-company journal or individual promoter transfer as an inter-company amount. |
| Security application or allotment money | Application, permitted use, allotment/refund dates, amount due on securities, approvals, bank trail, later conversion or cancellation | Leave old share-application money indefinitely in a non-deposit bucket. |
| Director or private-company director-relative amount | Status when received, source-of-funds declaration required by the rule, relationship evidence, agreement, bank credit, repayments, interest and Board records | Use current shareholding or a later appointment to prove director status at receipt. |
| Bond, debenture, commercial paper, or instrument | Instrument terms, security or charge, convertibility, tenure, listing or regulatory conditions, issue and redemption evidence | Assume every convertible or secured document is not a deposit. |
| Employee, trust, or business advance | Employment contract and limits; trust purpose; customer/supplier contract, allocation, performance, refund, dispute, age and prescribed conditions | Call a refundable or stale receipt an advance because it entered a revenue-related ledger. |
| Promoter, member, shareholder, or other founder support | Identity and legal capacity, lender requirement if relevant, declaration, agreement, purpose, tenure, repayment, interest, approvals and exact rule limb | Treat shareholder, promoter, founder and director as interchangeable categories. |
Rule 2(1)(c) contains detailed wording, conditions, provisos, time limits, source requirements, and consequences when an amount stops meeting a condition. The matrix is an evidence-routing tool, not a substitute for that text. Cite the precise limb beside each conclusion. If no reviewer can state the limb and conditions, keep the amount unresolved instead of forcing it into 'deposit' or 'not a deposit'.
Reconcile books, audit schedules, and financial statements
- 01
Freeze the population
Extract every outstanding receipt of money or loan as at the review date from loan, advance, deposit, security, share application, inter-company, related-party, customer, employee, vendor, suspense, and other relevant accounts. Search bank narrations and prior-year schedules for items hidden by netting or journals.
- 02
Roll each item forward
Prove opening balance plus receipts plus or minus supported adjustments less repayments equals closing balance. Keep principal, interest, conversion, waiver, set-off, foreign-exchange movement, and reclassification separate. Assign every difference to an owner.
- 03
Attach transaction evidence
Link counterparty status, agreement, declaration, Board or member approval, bank trail, security or charge, allotment, invoice or supply evidence, repayment terms, confirmation, dispute and later events. Evidence must support the condition at the relevant time, not only at year-end.
- 04
Tie to audited reporting
Reconcile the classified schedule to the trial balance, audited balance sheet, notes, related-party disclosures, cash-flow information and auditor working. G.S.R. 663(E) added an auditor declaration to DPT-3; a form total that does not tie to audited records is not ready.
- 05
Compare prior filings
Roll forward the prior DPT-3 purpose and schedules. Explain new items, repayments, reclassifications and corrections. Do not erase a prior treatment merely to force the current form to validate.
- 06
Select the purpose last
Only after scope, classification, reconciliation and auditor review should the compliance owner select deposit, non-deposit, combined, historical one-time, no filing, or advice needed. Verify current rules and the live MCA service at filing time.
Escalate classification and filing exceptions early
- Entity may be a government company, banking company, registered NBFC, housing-finance or another regulated or specified class needing a separate scope check.
- Money came from a person whose director, relative, member, promoter, company, foreign, or institutional status is disputed or changed around the receipt date.
- A Rule 2(1)(c) condition, declaration, allotment, use, security, tenure, refund, or repayment step is missing or expired.
- Books, bank, confirmation, agreement, Board record, financial-statement note, auditor schedule, and prior DPT-3 do not reconcile.
- The proposed current non-deposit or combined purpose relies only on a form dropdown and not a documented reading of Rules 16/16A and current MCA instructions.
- A prior one-time return, current annual return, late filing, correction, deposit default, public invitation, repayment failure, or penalty question is involved.
Sources and review
Published by ThynkBored. Published 13 July 2026. Content review completed 13 July 2026.
- Companies Act, 2013 — section 2(31): definition of deposit
India Code, Government of India. Accessed 13 July 2026.
Supports: Deposit begins with a broad receipt-of-money concept including deposit, loan, or another form; Categories prescribed in consultation with the Reserve Bank of India may fall outside that definition.
- Companies Act, 2013 — section 73: Prohibition on acceptance of deposits from public
India Code, Government of India. Accessed 13 July 2026.
Supports: Deposit acceptance is governed by statutory conditions and is not decided by a DPT-3 dropdown; Banking companies, registered non-banking financial companies, and other specified companies require an entity-scope check; Member deposits, repayment, security, default, and reserve questions sit outside a simple classification label.
- Companies Act, 2013 — section 76: Acceptance of deposits from public by certain companies
India Code, Government of India. Accessed 13 July 2026.
Supports: Only qualifying public companies may use the section 76 public-deposit route subject to its conditions; A private-company DPT-3 review must not imply authority to accept public deposits.
- G.S.R. 663(E), Companies (Acceptance of Deposits) Amendment Rules, 2022
Gazette of India, Ministry of Corporate Affairs. Accessed 13 July 2026.
Supports: Rule 16 auditor declaration added to DPT-3; Notified form purposes for deposits, transactions not treated as deposits, combined reporting, and the one-time return; Detailed Rule 2(1)(c) receipt categories and form schedules require item-level classification and age analysis.
- G.S.R. 341(E), Companies (Acceptance of Deposits) Second Amendment Rules, 2019
Gazette of India, Ministry of Corporate Affairs. Accessed 13 July 2026.
Supports: Rule 16A(3) one-time return used the fixed 31 March 2019 reference date; The one-time reporting period is historical and must not be reset as a recurring current annual date.
- Instruction Kit for Form No. DPT-3
Ministry of Corporate Affairs. Accessed 13 July 2026.
Supports: Current MCA operational description of Rule 16 annual deposit reporting and audited 31 March information; Operational description of the fixed Rule 16A one-time non-deposit return; Mutable form instructions remain subordinate to the Act, Rules, and Gazette-notified form.
This guide is educational and does not classify any receipt, decide whether a company must file DPT-3, authorise acceptance of deposits, or determine a deposit, non-deposit, combined, nil, one-time, late, or correction route. Entity type, banking or NBFC registration, government ownership, counterparty status at receipt, source of funds, declaration, instrument, security, allotment, use, tenure, repayment, interest, foreign-exchange rules, related-party facts, private-company exemptions, later events, prior filings, audited statements, amendments, notifications, and live MCA workflow can change the result. Rule 2(1)(c) must be read in full for the exact limb and every condition. The historical one-time return must not be presented as a current annual requirement. Official form options and instruction kits must be reconciled with Rules 16 and 16A. Obtain company-secretary, legal, accounting, and auditor review for unresolved or material items, and never back-date, relabel, net, or omit a balance to produce a preferred form result.
Find the unresolved money before choosing a form purpose
Share the company type, broad regulatory status, financial year, approximate total outstanding, high-level receipt categories, prior DPT-3 purpose, audit stage, and nearest filing decision. ThynkBored can help structure the classification and exception queue without deciding a transaction from its label.
List record categories and status only, such as trial balance, receipt schedule, agreements, declarations, Board records, bank reconciliation, confirmations, audited financial statements, auditor schedule, and prior DPT-3. Do not send or upload ledgers, statements, agreements, declarations, identity or contact data, director or shareholder details, bank records, auditor files, Board minutes, financial statements, SRNs, MCA credentials, OTPs, passwords, DSC tokens or PINs, or document contents through the form; agree a secure handoff first.
Diagnose this issueQuestions owners ask
What is DPT-3 used for?
DPT-3 is the Companies (Acceptance of Deposits) Rules form used for the purposes shown in the current notified form, including deposit, transactions not treated as deposits, combined, and historical one-time reporting. The governing authority differs by purpose: Rule 16 addresses annual deposit reporting, while Rule 16A created a fixed historical one-time non-deposit return. Company scope and transaction classification must be reviewed before selecting a purpose.
What should founders prepare for DPT-3 review?
Prepare an item-level roll-forward of every outstanding receipt or loan, counterparty and status-at-receipt facts, agreements, declarations, approvals, bank trail, allotment or supply evidence, repayments and adjustments, exact proposed Rule 2(1)(c) limb, audited trial-balance and financial-statement reconciliation, auditor schedule, prior DPT-3 and an unresolved-item queue. Keep sensitive records out of public forms.
Useful context for this decision
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