Annual DIN and DPIN KYC.
This one is personal, not corporate. Anyone holding a director identification number files their own KYC by 30 September, whether or not they are on any board, whether or not the company trades, and whether or not they have used the number all year. Miss it and the number is deactivated — which means every filing that needs your signature stops.
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The obligation attaches to the number, not to the company.
Every individual who has been allotted a director identification number, and whose number is in approved status as on 31 March of a financial year, files their KYC by 30 September of the following financial year. There is no exception for someone who is not currently a director of anything, whose companies are dormant, or who has not touched the number since it was issued.
The same applies to a designated partner identification number. The two systems were merged some years ago, so a person who obtained a DPIN for an LLP files the same annual KYC as a company director does. People who hold both a directorship and an LLP partnership file once, for the one number they hold.
The consequence of missing it is mechanical and immediate. The number is marked deactivated for non-filing of KYC, and a deactivated number cannot be used to sign or file anything. Not the company's annual return, not a resignation, not a director appointment, not an LLP's Form 8.
That is why the failure surfaces at the worst possible moment. The accounts are ready in October, the form is drafted, and the signature fails because the number went inactive on 1 October. Reactivation is possible on payment of a fee, but it is a filing in itself, and it takes days that the deadline you were actually working to does not have.
Two routes, and one question decides which.
Has anything in your KYC details changed since you last filed?
| DIR-3 KYC (e-form) | DIR-3 KYC web service | |
|---|---|---|
| Who uses it | Anyone filing KYC for the first time, and anyone whose mobile number, email address or other particulars have changed | Anyone who has filed the e-form previously and whose particulars are unchanged |
| What it involves | A full form with identity and address documents attached | A verification of the details already on record, confirmed online |
| Verification | OTP to your own mobile and personal email, and your own digital signature | OTP to the mobile and email already on record |
| Professional certification | Certified by a chartered accountant, company secretary or cost accountant in practice | Not required |
| Effort | Documents to collect, attest and attach — plan for a few days | Minutes, provided the mobile and email on record still work |
The trap is the second row of the last column. The web service sends the OTP to the mobile number and email already on record, so if either has changed — a phone number given up years ago, an old work email — the web route silently fails and you have to file the full e-form instead. That discovery on 29 September is the reason this gets missed.
Six ways people lose their DIN.
"I am not a director of anything at the moment"
Irrelevant. The obligation attaches to holding the number, not to using it. People who resigned from every board years ago still hold an approved DIN, and still have to file KYC every year until the number is surrendered.
The email and phone on record are dead
The web service verifies by OTP to the details already on record. An old number, a work email from a previous employer, or a mailbox nobody checks means the OTP never arrives — and the fix is to file the full e-form, which needs documents and certification and days you may not have.
The digital signature had expired
The e-form is signed with your own digital signature certificate. A DSC that lapsed during the year has to be renewed first, and renewal has its own verification process. Checking it in August rather than late September removes the problem entirely.
The company assumed the director would do it, and vice versa
It is a personal filing, so no company owns it. In family groups where one person handles everything, the directors who are not involved in the paperwork are the ones whose numbers go inactive — and then nobody can sign anything.
It was discovered in October, with filings due
The deactivation takes effect the day after the deadline, which is precisely when the annual filing season starts. Reactivation is a filing with a fee and it takes time. Every downstream deadline keeps running while it is being sorted out.
A foreign national's documents were not ready
Where the holder is a foreign national, the passport is mandatory and the documents have to be attested in the manner the rules require — notarised and apostilled or consularised abroad. That is measured in weeks, and it cannot be started on the last weekend of September.
What you receive.
Straightforward, if it is started early.
Check the number and the history
Whether the DIN or DPIN is in approved status, when KYC was last filed against it, and whether the person holds more than one number — which is itself a problem needing separate correction.
Test the contact details
The mobile number and email on record are confirmed as live before anything is filed. This single step is what decides whether the whole exercise takes ten minutes or five days.
Confirm the digital signature
Validity checked, and renewal started where it has lapsed or expires before the deadline. For foreign nationals, the attestation of documents is started at this point because it is the long pole.
File the right form
The web service where the details are unchanged and the OTPs reach you. The full DIR-3 KYC, with documents and professional certification, where anything has changed or this is a first filing.
Confirm and record
The acknowledgement is retained and the status re-checked afterwards, so there is evidence the filing landed rather than an assumption that it did.
Coordinate across the group
Where the same people sit on several companies and LLPs, every number is tracked in one place. One deactivated DIN can stop filings for an entire group of entities, so they are managed together rather than individually.
Four things to start.
The number itself
And, for a group, every number held by everyone involved.
- DIN or DPIN, and the name it is held in
- Whether KYC has been filed before, and when
- Whether the number is currently active
Live contact details
A personal mobile and a personal email you actually use — not a company address someone else monitors.
- Personal mobile number
- Personal email address
- Whether either has changed since the last filing
Identity and address proof
Needed for a first filing or where details have changed.
- PAN, and passport where the holder is a foreign national
- Proof of present address
- Date of birth as it appears on the record
Digital signature
The e-form cannot be filed without one in the holder's own name.
- Whether a DSC exists and when it expires
- Whether it is registered against the DIN
- Who holds the token
What this looks like in Goa.
The deadline lands as the season is being prepared for, and the consequence lands in October when the annual filings are due. Doing the KYC in July costs nothing and removes the collision entirely.
The relative added as a second director years ago holds a live DIN and an obligation nobody has told them about. Their number goes inactive, and the company's filings stop because the second signature is unavailable.
Goa families with members abroad hold DINs that need the same annual KYC. Where documents have to be attested overseas, the process runs into weeks and cannot be started in late September.
Numbers issued a decade ago carry the phone and email of that time. Almost every failed web filing we see comes down to an OTP sent to a number that stopped working years ago.
Where the same two or three people are directors and designated partners across several companies and LLPs, one deactivated number blocks filings across all of them. They are best tracked as a group rather than entity by entity.
Usually needed alongside this.
DIN and DPIN KYC, answered.
Who has to file DIN KYC?
Every individual who holds a director identification number in approved status as on 31 March of a financial year, by 30 September of the following financial year.
There is no exception for someone who is not currently a director of any company, whose companies are dormant, or who has never used the number. The obligation attaches to holding the number. The same applies to a designated partner identification number, since the two systems were merged.
What is the difference between DIR-3 KYC and the web service?
DIR-3 KYC, the full e-form, is used by anyone filing for the first time and by anyone whose mobile number, email address or other particulars have changed. It carries identity and address documents and is certified by a chartered accountant, company secretary or cost accountant in practice.
The web service is for people who have filed the e-form previously and whose details are unchanged. It confirms the details already on record by OTP and takes minutes. If the mobile or email on record no longer works, the web route fails and the e-form has to be filed instead.
What happens if I miss the deadline?
The number is marked deactivated for non-filing of KYC, and a deactivated number cannot be used to sign or file anything — not an annual return, not a resignation, not an appointment, not an LLP form.
It can be reactivated by filing the KYC with the prescribed fee. That is a filing in its own right and it takes time, which is the real cost: the deactivation takes effect exactly as the annual filing season begins.
Is there a fee?
No fee if the KYC is filed on or before the due date. Once the number has been deactivated for non-filing, a prescribed fee is payable to reactivate it.
Since the on-time filing costs nothing and takes minutes through the web service, the fee is entirely avoidable. It is one of the few compliances where being organised has a direct and immediate saving.
I resigned from all my companies. Do I still have to file?
Yes, for as long as you hold the number. Resigning from a board does not surrender your DIN — the number stays with you, and so does the annual KYC obligation.
If you genuinely have no intention of being a director again, the number can be surrendered through a separate application, subject to conditions including that it has never been used for a directorship or that all such directorships have ended. Until that is done, the annual KYC continues to apply.
Do LLP designated partners file the same KYC?
Yes. The designated partner identification number and the director identification number systems were merged, so a person holding a DPIN files the same annual KYC.
Someone who is both a company director and an LLP designated partner holds one number and files once. The consequence of missing it reaches both: a deactivated number blocks the company's filings and the LLP's Form 8 and Form 11 alike.
Can somebody else file it for me?
A professional prepares and certifies the e-form, but the filing cannot be completed without you. The OTPs go to your personal mobile and your personal email, and the form is signed with your digital signature.
That design is deliberate — it is a verification of the individual, not of the company. It also means a director who is travelling or unreachable in late September genuinely cannot be covered for by anyone else.
What if my registered mobile or email has changed?
Then the web service will not work, because the OTP goes to the details already on record. You file the full DIR-3 KYC e-form instead, which updates the particulars as well as completing the KYC.
That means documents, attestation and professional certification — a few days of work rather than a few minutes. This is the single most common reason a KYC that was going to be done on the last day is not done at all, and checking the details in August avoids it completely.
What documents are needed for a foreign national?
A passport is mandatory, together with proof of present address. The documents must be attested in the manner the rules prescribe — typically notarised and apostilled or consularised in the country where they are executed.
That attestation is measured in weeks, not days, and it cannot be compressed at the end of September. Where an overseas director is involved, the KYC is started in July as a matter of routine.
How do we manage this across a group of companies?
By tracking the people rather than the entities. Where the same two or three individuals sit on several companies and LLPs, one deactivated number stops filings across all of them, and the failure is not visible from any single entity's compliance list.
The practical approach is a single register of everyone's number, KYC status, DSC expiry and current contact details, reviewed each July. It takes an afternoon once a year and prevents the October scramble entirely.
Send the DIN and the mobile number on record.
If the number still receives messages, this is a ten-minute job. If it does not, better to find out in July than on 29 September. For a group, send everyone's numbers together and we will track them as one.