Post-Incorporation Compliance Checklist for FPOs (2025)

What Every Farmer Producer Organisation Must Do After Registration

By Prashant Kumar

Introduction

Registration gives your FPO a legal identity — but compliance keeps it alive.
Once incorporated under the Companies Act, 2013, a Farmer Producer Organisation must follow a defined set of post-registration obligations to remain legally valid, fund-ready, and credible.

These include board meetings, statutory audits, ROC filings, and member record maintenance under the MCA’s V3 portal. Most importantly, timely compliance determines eligibility for SFAC grants, NABARD support, and government procurement tie-ups.

If you’ve just completed registration (see our FPO Registration Guide), here’s your complete 12-month compliance roadmap for 2025.

What Is Post-Incorporation Compliance for FPOs?

Post-incorporation compliance refers to all legal and regulatory tasks an FPO must complete after registration — from holding the first board meeting and appointing an auditor to filing annual returns and maintaining member records under the Companies Act, 2013 and MCA V3 portal.

Step-by-Step Compliance Calendar for FPOs (2025)

01. First Board Meeting – within 30 days

Hold the first meeting of directors within 30 days of incorporation.
Agenda should include: appointment of the first auditor, approval of bank signatories, share allotment confirmation, and adoption of the registered office address.
Record minutes and preserve them in the statutory minutes book.

02. Appointment of Statutory Auditor

Appoint a Chartered Accountant within 30 days (Form ADT-1 to ROC).
The auditor’s report will be required for funding and annual filing purposes.

03. Issue of Share Certificates – within 60 days

Issue share certificates to all subscriber members. Update the Register of Members and the Share Allotment Registerwith signatures of two directors or one director and the company secretary.

04. Maintenance of Statutory Registers

Under Section 88 and 189 of the Companies Act, an FPO must maintain:

• Register of Members and Share Transfers
• Register of Directors and KMP
• Minutes Book for Board and General Meetings
• Register of Loans, Guarantees, and Investments
• Financial and accounting records

Keeping digital copies under MCA V3 is permitted and advisable.

05. PAN, TAN, and Bank Account

Ensure PAN and TAN are generated through SPICe+ or applied separately via NSDL.
Open a current account in the name of the FPO and deposit members’ capital.
Bank details are essential for availing SFAC Equity Grant and Credit Guarantee benefits (see our funding guide).

06. GST and Other Optional Registrations

If the FPO trades in goods or services exceeding the prescribed threshold, apply for GST registration.
Consider Udyam Registration (for MSME benefits) and APEDA Registration (for export activities).

07. Annual ROC Filings – Key Forms

Every Producer Company must file:

• AOC-4: Financial Statements (within 60 days of AGM)
• MGT-7A: Annual Return (within 60 days of AGM)
• DIR-3 KYC: Annual Director KYC (by 30 September)
• ADT-1: Auditor appointment (within 15 days of AGM or Board meeting)

File via MCA V3 portal using your FPO’s digital signature and director DINs.

08. Annual General Meeting (AGM)

Hold the first AGM within nine months of closing the first financial year; thereafter within six months each year.
AGM agenda includes:

• Approval of financial statements
• Appointment of auditor and directors
• Approval of member patronage bonus or surplus distribution

Maintain attendance records and signed minutes for inspection readiness.

09. Accounting, Audit & Recordkeeping

Maintain books of account as per Section 128 of the Companies Act: cash book, ledger, journal, and member-wise transaction record.
Audit annually through the appointed CA. Audited accounts are mandatory for SFAC, NABARD, and cooperative funding eligibility.

10. Taxation & Regulatory Filings

Even if agricultural income is largely exempt, FPOs must file ITR-6 annually.
Segregate agricultural and non-agricultural income clearly.
Refer to our article [FPO Taxation and Accounting Rules in India (2025)] for a deeper explanation.

Governance Best Practices for Producer Companies

• Conduct at least four board meetings per year, spaced 90 days apart.
• Circulate meeting notices at least seven days in advance.
• Record attendance, quorum, and resolutions accurately.
• Display transparency in member transactions and patronage distribution.

Governance quality directly impacts investor and grantor trust.
Our next article on FPO Governance and Management Structure (2025) explores these responsibilities in detail.

Common Mistakes That Trigger Non-Compliance Notices

• Missing the first Board Meeting deadline.
• Failing to issue share certificates within 60 days.
• Late filing of AOC-4 and MGT-7A.
• Inaccurate member records or lack of updated registers.
• Using personal bank accounts for FPO transactions.

Such lapses can attract penalties and restrict access to institutional grants.

Why Compliance Matters for Funding and Credibility

A compliant FPO is automatically eligible for SFAC, NABARD, and NCDC support, as these agencies verify ROC filings and audit reports before sanctioning any financial aid.
Compliance is not just paperwork — it’s the proof of governance, transparency, and readiness to grow.

For funding guidance, visit SFAC Schemes and Funding Support for FPOs in India — part of our FPO Legal Series.

About the Author

Prashant Kumar is a Company Secretary, Published Author, and Partner at Eclectic Legal, a full-service Indian law firm advising on corporate, regulatory, and transactional matters. He specialises in FPO structuring, agricultural law, and corporate compliance, helping farmer groups, startups, and agri-businesses build legally sound and sustainable organisations.
📩 prashant@eclecticlegal.com | ☎️ +91-9821008011