India – Changes to DIN KYC Filing Requirements

India’s Ministry of Corporate Affairs (MCA) has introduced significant changes to the Director Identification Number (DIN) Know Your Customer (KYC) requirements, replacing the former annual filing obligation with a triennial filing system.

Effective 31^st of March 2026, directors will only be required to submit a simplified KYC form once every three years for verification, updates to personal information, and DIN reactivation where applicable.

For directors who are already KYC‑compliant, the next filing deadline under the new framework will be the 30^th of June 2028.

Regulatory Background

Following the Rules amendment notification issued on the 31^st of December 2025, the MCA has transitioned from an annual verification model to a triennial KYC cycle.

The consolidated KYC form supports several administrative functions, including:

• Verification of KYC compliance
• Updates to mobile and email contact details
• Amendments to residential address information
• Reactivation procedures for deactivated DINs

To Whom Do the Requirements Apply?

All individuals who hold a Director Identification Number (DIN).

What is a DIN?

A Director Identification Number (DIN) is a mandatory, unique eight‑digit identifier issued by the Ministry of Corporate Affairs to individuals serving as company directors in India.

The DIN is:

• Personal to the director (not linked to any specific company)
• Valid for a lifetime
• Required for signing filings submitted to the Registrar of Companies (ROC)

Required Actions

Directors with completed KYC filings will automatically transition to the triennial schedule, with their next KYC due by the 30^th of June 2028.

Directors whose DINs remain deactivated may continue using the existing reactivation process until the 31^st of March 2026.

Risks of Non-Compliance

Failure to file Form DIR 3 KYC may result in:

• DIN deactivation
• Inability to sign ROC forms
• A statutory penalty of ₹5,000 for delayed filing

How Mercator® by Citco (Mercator) Can Help

Our team can assist with reviewing, preparing, and submitting your DIN KYC filings to ensure timely and compliant updates. For support, please contact mercator@citco.com