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Pathak Associates

DIN KYC

Annual DIN Know Your Customer compliance to keep director identification active.

DIR-3 KYC is an annual declaration confirming that a director's details are current, due by 30 September each year for anyone holding a DIN. Miss it and the DIN is deactivated — not cancelled, but unusable — which blocks every filing that needs that director's signature until ₹5,000 is paid to reactivate it. For a company with two directors that is an inconvenience; for an OPC or a company where one director signs everything, it stops the company filing anything at all.

Who this is for

  • Annual KYC
  • DIN activation
  • Easy online process
  • Penalty avoidance

The process

What we actually do

  1. 1

    We check which form applies

    DIR-3 KYC is the full form, required the first time and whenever details have changed. DIR-3 KYC-WEB is a simple OTP confirmation for anyone whose details are unchanged from last year, and it takes minutes.

  2. 2

    We verify the contact details before filing

    The form is authenticated by OTP to the registered email and mobile. A stale number is the commonest reason a KYC filing fails at the last step, and updating it requires the full DIR-3 KYC rather than the web version.

  3. 3

    We file before 30 September

    There is no grace period. The DIN is deactivated the day after, and reactivation costs ₹5,000 regardless of how soon afterwards it is noticed.

  4. 4

    We reactivate deactivated DINs

    Filing the KYC with the ₹5,000 fee restores the DIN. Where several directors of the same company have lapsed together — which happens, because they were all allotted at incorporation — we handle them as a set.

  5. 5

    We diarise it against every DIN you hold

    The obligation is per person, not per company. Someone on four boards files once; someone who resigned from all of them still files.

Who this is for

  • Every person holding a DIN, whether or not they are currently a director of anything
  • Directors who have resigned but still hold the DIN — the obligation follows the number, not the office
  • Anyone whose DIN has already been deactivated and needs reactivating
  • Directors whose registered email or mobile has changed since the last filing

How long it takes

Same day for the web version where details are unchanged. One to two working days for the full DIR-3 KYC, and the same to reactivate a deactivated DIN once the fee is paid.

If you do nothing

The DIN stays deactivated and the company's filings stop. Because the annual filing fee continues to run at ₹100 a day per form while nobody can sign them, a missed ₹5,000 KYC routinely turns into a five-figure additional fee on filings that were otherwise ready to go.

The law, in figures

Dates, thresholds and sections

Every figure below carries the provision it comes from, so it can be checked.
WhatFigureSource
Due date30 September each yearRule 12A, Companies (Appointment and Qualification of Directors) Rules 2014
FormDIR-3 KYC, or DIR-3 KYC-WEB where details are unchangedRule 12A, proviso
Consequence of not filingDIN deactivatedRule 11(2), Companies (Appointment and Qualification of Directors) Rules 2014
Reactivation fee₹5,000Companies (Registration Offices and Fees) Rules 2014
Who must fileEvery DIN holder, whether or not currently a directorRule 12A

What usually goes wrong

  • Assuming it does not apply because you resigned — the obligation follows the DIN, not the directorship
  • Leaving a stale mobile or email on the DIN, so the OTP never arrives
  • Discovering the deactivation only when a company filing is rejected, often close to a deadline
  • Filing the web version when details have changed, which requires the full form
  • Letting every director of a small company lapse together, which blocks all filings at once
  • Filing the KYC against a DIN you no longer use and forgetting the one you do
  • Leaving it to September, when the portal is at its busiest and an OTP failure has no time to spare

What non-compliance costs

  • DIN deactivated from 1 October
  • ₹5,000 to reactivate, regardless of the delay
  • Every filing requiring that director's digital signature is blocked in the meantime
  • Where the deactivation causes annual filings to be late, the ₹100-a-day fee runs on those as well

These are statutory amounts, not our fees. What we charge depends on your situation and is quoted before any work starts.

Not to be confused with

These come up in the same conversation and are routinely treated as the same thing. They are not.

DSC renewal

A digital signature certificate expires on its own cycle and is renewed with the certifying authority. DIN KYC is an annual MCA filing. Both can block a filing, for different reasons, and they lapse independently.

Company annual filing

AOC-4 and MGT-7 are filed by the company about its own year. DIR-3 KYC is filed by an individual about themselves, on a different date, and applies even to someone who is not currently a director of anything.

DIR-12

DIR-12 records a change of director and is filed by the company within thirty days of the event. KYC is an annual confirmation filed by the director, whether or not anything has changed.

Work like this

Terms you will come across

DIN
A DIN is the eight-digit number the Ministry of Corporate Affairs allots to an individual so they can be appointed a director of a company, and it is held for life.

Related services

DIN KYC

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