The MCA V3 annual-return workflow has raised questions about how companies should provide supporting MGT-8 certification documents.<\/p>\r\nThe Institute of Company Secretaries of India addressed this in its advisory dated 24 December 2025.\r\n
Why is an optional attachment being discussed?<\/h2>\r\nThe ICSI advisory explains that MGT-8 certification has been integrated into the MGT-7 e-form as a static field. It also refers to the MCA FAQ position on using the optional attachment field for qualifying remarks.\r\n\r\nICSI recommends that practising professionals continue to prepare certification on the letterhead of a Peer Reviewed Practice Unit, generate a UDIN in accordance with its guidelines and attach the document as an optional attachment to MGT-7 and MGT-7A wherever applicable, pending further MCA clarification or rules.\r\n
Is the attachment a statutory requirement for every company?<\/h2>\r\nDo not assume that it is. The advisory is professional guidance, and it does not say that every company must upload an MGT-8 certificate regardless of applicability.\r\n\r\nThe underlying Section 92(2) criteria must first be checked. Listed companies and companies meeting the prescribed paid-up capital or turnover thresholds should coordinate with their practising Company Secretary.\r\n
What should the company confirm?<\/h2>\r\nBefore submission, clarify:\r\n\r\n \t
Whether MGT-8 certification applies to the company.<\/li>\r\n \t
Whether the professional has completed the required examination.<\/li>\r\n \t
Whether a supporting certificate is being prepared.<\/li>\r\n \t
Whether UDIN requirements apply to the professional's document.<\/li>\r\n \t
Whether the current portal provides the relevant optional attachment field.<\/li>\r\n \t
Whether MCA has issued a later clarification.<\/li>\r\n<\/ol>\r\n