DIR 3 KYC Web three year cycle: compliance guide for directors and companies

The Ministry of Corporate Affairs has notified a new framework for director KYC. Through a notification dated 31 December 2025 (GSR 943(E)), the existing DIR 3 KYC and DIR 3 KYC Web filings are being streamlined into a single Form DIR 3 KYC Web with a three year filing cycle, effective from 31 March 2026.

For company secretaries, in house legal teams and compliance professionals, this is an important change that will impact annual calendars, DIN registers and internal workflows. This guide summarises the new position, explains the official MCA illustrations, and sets out practical steps for implementation.

Related: Director KYC and DIN management checklist for Indian companies (link: /blog/director-kyc-din-management-checklist-india)

Legal background and notification reference

The director KYC framework flows from provisions of the Companies Act 2013 and the Companies (Appointment and Qualification of Directors) Rules. Over time, MCA introduced Form DIR 3 KYC and later the web version to ensure that director particulars remained current in its records.

The latest amendment notifies:

• Substitution of Form DIR 3 KYC and DIR 3 KYC Web by a single Form DIR 3 KYC Web.
• Introduction of a three year filing cycle for routine director KYC, anchored to the financial year in which DIN is allotted and the status as on 31 March of a year.
• Continued obligation to update changes in contact details and address within 30 days through DIR 3 KYC Web with applicable fees under the Companies (Registration Offices and Fees) Rules 2014.

The policy objective is to reduce repetitive compliance burden while strengthening the overall quality of director data on the MCA21 portal.

Core compliance requirements under new DIR 3 KYC Web

The key obligations can be summarised as follows:

1. Directors who hold a DIN as on 31 March of a financial year will be required to file Form DIR 3 KYC Web once in every third consecutive financial year, on or before 30 June of that year.

2. Any change in a director s mobile number, email ID or residential address must be updated within 30 days through Form DIR 3 KYC Web, with payment of the prescribed fee.

3. Non filing may still lead to consequences such as the DIN being marked as deactivated due to non compliance, along with the requirement to pay additional fees for restoration.

In practice, companies need to track both the three year cycles and intervening changes for each DIN.

Understanding the MCA illustrations in practical terms

The MCA communication includes three illustrations that clarify how the three year cycle will work. Translating these into practical compliance terms helps avoid confusion.

Illustration 1: new DINs in FY 2025 26

Where a DIN is allotted during financial year 2025 26, Form DIR 3 KYC Web is to be filed once every three consecutive financial years. The first filing becomes due between April 2029 and June 2029, and subsequently every third financial year.

Key takeaway:

• For DINs allotted in FY 2025 26, the first routine KYC under the three year cycle is effectively deferred until FY 2028 29 (April June 2029 window).

Illustration 2: existing DINs where KYC is filed for FY 2025 26

Where a director who holds a DIN as on or before 31 March 2025 has already filed DIR 3 KYC eform or DIR 3 KYC Web for FY 2025 26, no further KYC filing will be required for FY 2026 27 and 2027 28, provided there is no change in KYC particulars.

In such cases, the first filing under the new cycle will fall due between April 2028 and June 2028.

Key takeaway:

• Existing directors with up to date KYC as of FY 2025 26 effectively get a two year break before the next routine filing.

Illustration 3: DIN allotted on 1 January 2026 and KYC updated in 2027 28

Where a DIN is allotted on 1 January 2026 (that is, in FY 2025 26) and the director later updates mobile number, email ID or residential address in FY 2027 28 by filing DIR 3 KYC Web, the three year cycle is still reckoned from FY 2025 26.

This means:

• Next routine KYC under DIR 3 KYC Web will be due from April 2029 to June 2029.
• The update made in FY 2027 28 does not reset the three year cycle.

Key takeaway:

• Change filings do not restart the clock. Compliance teams must track the original allotment year for each DIN.

Suggested compliance approach for companies and professionals

To operationalise the new regime effectively, companies can adopt a structured approach.

1. Update the DIN register

Maintain an updated DIN register capturing at minimum:

• Director name
• DIN
• Date of DIN allotment
• Date of last DIR 3 KYC or DIR 3 KYC Web filing
• Next routine KYC window under the new three year cycle
• Dates of any change filings for mobile, email or address

This register can sit alongside the register of directors required under company law.

2. Revise the annual compliance calendar

Existing calendars built around yearly DIR 3 KYC filings should be revised. For each DIN, diarise:

• The relevant three year window, with internal reminders at least one month before the statutory deadline of 30 June.
• A standing item that any change in director contact details must be reported to the company secretary or compliance team within a specified internal timeline, so that the 30 day legal window can be met.

3. Create internal SOPs for change events

Many non compliance issues arise when directors change mobile numbers or email IDs without informing the company. A simple written SOP can require:

• Directors to immediately inform the company secretary of any change in contact details or residential address.
• The company to initiate a DIR 3 KYC Web change filing within a set number of working days.
• Documentation of evidence supporting the new address, where required.

4. Coordinate across group entities and professional firms

Where directors sit on boards of multiple group companies, or where a professional firm of company secretaries manages compliance for several entities, coordination becomes critical.

• Consider designating one entity or firm as the anchor for monitoring DIN KYC status, with information shared with all related companies.
• Avoid duplicate or inconsistent filings by ensuring that a single source of truth exists for DIN and KYC information.

Related: Group level governance practices for Indian business families and holding structures (link: /blog/group-governance-practices-india)

Impact assessment for directors and boards

From a governance perspective, the new DIR 3 KYC Web regime:

• Reduces mechanical annual filings and associated costs.
• Places more emphasis on maintaining up to date records when there is an actual change in particulars.
• Requires better tracking of the three year cycle, which may not align neatly with financial year routines for every director.

Boards should be briefed on these changes and reassured that the compliance obligation is becoming lighter, not heavier, provided that internal information flows are robust.

Independent directors and nominee directors in particular should be encouraged to treat KYC updates as part of their standard obligations when they join or leave boards, change their contact details or relocate.

How FastLegal can assist

FastLegal works with businesses, company secretaries and professionals across India on routine MCA compliance and governance structuring. The new DIR 3 KYC Web regime is a good opportunity to:

• Clean up DIN and director records.
• Implement a unified DIN register and compliance calendar.
• Train directors and finance or HR teams on the new process.

If you want help in assessing your current director KYC status, mapping three year cycles, or integrating these changes into your broader corporate governance framework, you can reach out through the FastLegal contact page.

Related: Annual ROC and MCA compliance services for Indian private companies (link: /blog/roc-mca-compliance-services-india)