MCA Amends DIN KYC Provisions: What Has Changed Under the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025
The Ministry of Corporate Affairs (MCA) has notified the Companies (Appointment and Qualification of Directors) Amendment Rules, 2025 vide Gazette Notification dated 31 December 2025. These rules amend the Companies (Appointment and Qualification of Directors) Rules, 2014 and shall come into force from 31 March 2026.
It is important to clarify that DIN KYC is not a new compliance requirement. The amendment does not introduce DIN KYC for the first time, but modifies and restructures the existing DIN KYC framework, which has been in force for several years.
Evolution of DIN KYC – A Brief Background
Introduction of DIN KYC (2018)
- MCA introduced mandatory DIN KYC vide notification dated 21 June 2018
- Rule 12A was originally inserted, requiring:
- Every DIN holder to file DIR-3 KYC
- Filing to be done annually, on or before 30th September.
- Non-filing resulted in DIN deactivation
Later, MCA introduced DIR-3 KYC-Web, allowing web-based annual confirmation for directors who had already filed KYC once.
Till now, DIN KYC was:
Annual
Uniform for all DIN holders
Not clearly event-based
What Has Changed Under the 2025 Amendment?
The 2025 amendment restructures Rule 12A and introduces a dual-compliance model:
- Periodic KYC (Once in Three Years)
- Mandatory Event-Based KYC (Within 30 Days of Change)
This is a shift from annual routine filing to risk-based and event-based compliance.
New Rule 12A – Explained Simply
Periodic DIN KYC (Once Every 3 Years)
Under the amended Rule 12A:
Every DIN holder must file DIR-3 KYC-Web
By 30th June
Every third consecutive financial year
This replaces the earlier annual mandatory filing requirement.
Event-Based DIN KYC (New & Important)
If there is any change in the following particulars:
- Mobile number
- Email ID
- Residential address
The DIN holder must update the KYC within 30 days of such change, along with prescribed fees.
This obligation applies irrespective of whether the periodic KYC year has arrived or not.
Comparison: Earlier vs Amended DIN KYC Rules
| Particulars | Earlier Rule (2018–2025) | Amended Rule (2025) |
|---|---|---|
| Nature of filing | Annual | Once in 3 years + event-based |
| Due date | Every year by 30 September | 30 June of 3rd FY |
| Change in details | No clear timeline | Mandatory within 30 days |
| Compliance approach | Routine | Risk-based & continuous |
Practical Examples for Better Understanding
Example 1: Periodic KYC Cycle
Mr. X obtained DIN in FY 2025-26.
| Financial Year | Status |
|---|---|
| FY 2025-26 | 1st year |
| FY 2026-27 | 2nd year |
| FY 2027-28 | 3rd consecutive year |
Mr. X must file DIR-3 KYC-Web by 30 June 2028.
Earlier, he would have filed KYC every year. Now, filing is required once in three years, unless details change.
Example 2: Change in Email ID (Event-Based KYC)
Ms. Y last filed her DIN KYC in FY 2024-25.
Her next periodic KYC is due in FY 2027-28.
She changes her email ID on 15 April 2026.
Despite her next periodic cycle being far away, she must:
- File DIR-3 KYC-Web
- On or before 15 May 2026
This is a new compliance obligation introduced by the amendment.
Revised DIR-3 KYC-Web Form
The notification also provides a revised DIR-3 KYC-Web, requiring:
- OTP-based verification of mobile & email
- Updated address details
- PAN / Passport validation
- Declaration and professional certification (CA / CS / CMA)
Consequences of Non-Compliance
Failure to comply with Rule 12A may result in:
- Deactivation of DIN
- Inability to:
- File MCA forms
- Act as director
- Late fees for reactivation
Effective Date of Amendment
Effective from: 31 March 2026
The amended compliance structure will apply from FY 2026-27 onwards.
Conclusion
DIN KYC has existed since 2018, but the 2025 amendment marks a fundamental change in its compliance philosophy. The focus has shifted from annual routine filing to periodic and event-based verification, increasing accountability of directors while reducing unnecessary annual filings. Directors and companies should review their DIN KYC calendars and internal processes to align with the amended Rule 12A and avoid future non-compliance.