MCA Extends Due Dates for LLP BEN-2 and Form 4D

Introduction

On May 7, 2024, the Ministry of Corporate Affairs (MCA) issued General Circular No. 3/2024, allowing LLPs to file LLP BEN-2 and LLP Form No. 4D without any additional fees until July 1, 2024. The circular has been addressed to all Regional Directors, Registrars of Companies, and relevant stakeholders.

LLP BEN-2 and LLP Form No. 4D are mandatory filings under the Limited Liability Partnership Act, 2008, used to report beneficial ownership details. Ensuring timely LLP compliance is essential to avoid legal penalties.

What is LLP BEN-2?

LLP Form BEN-2 is a statutory filing required for Limited Liability Partnerships (LLPs) in India. Introduced in 2023, it is used to report details of Significant Beneficial Owners (SBOs) to the Registrar of Companies (ROC). When an LLP identifies an SBO, it must first obtain a declaration from that individual and then file Form BEN-2 within 30 days of receiving the declaration. This process ensures transparency regarding the individuals who ultimately own or control the LLP.

What is LLP Form No. 4D?

LLP Form No. 4D, also introduced in 2023, is another compliance requirement for LLPs. This form captures information related to the beneficial interest in contributions received by the LLP, regardless of the source. By filing Form 4D, LLPs disclose who ultimately benefits from the capital invested, thereby strengthening transparency and accountability in ownership structures.

MCA Relaxation Measures for LLP Forms

To support the smooth transition from MCA-21 Version 2 to Version 3 and to promote better compliance, the Ministry of Corporate Affairs (MCA) has extended the deadline for filing LLP BEN-2 and LLP Form No. 4D. LLPs can now submit these forms without any additional fees until July 1, 2024. The circular was issued with approval from the competent authority and signed by Dr. Amit Kumar, Deputy Director (Policy).

Reasons for the MCA Relaxation Measures

The MCA recognizes that LLPs may face challenges during the ongoing MCA-21 system migration. To ease this transition, the relaxation measures aim to:

Reduce compliance burden during the system upgrade.
Encourage LLPs to complete timely filings and maintain statutory compliance.

About the Author

Ravi

Ravi is a seasoned legal writer who distills complex laws into clear, practical insights. He helps entrepreneurs understand their legal obligations with confidence, enabling them to build compliant and sustainable businesses.