Producer Company Complainces

✅ Producer Company Compliances

A Producer Company is formed by farmers / agriculturists / producers to work together for better prices, shared resources, and collective growth.

Even though it works like a cooperative, legally it is treated as a company, so compliances are similar to a Private Limited Company — but with some special rules.

1️⃣ Mandatory Annual Compliances

  • ✔ AOC-4 (Financial Statements)
  • Every Producer Company must file its annual accounts.
  • Due Date:
  • 📅 30 September (for most companies, unless extended)
  • ✔ MGT-7 (Annual Return)
  • Annual return containing member details, capital, directors etc.
  • Due Date:
  • 📅 29 November (60 days from AGM)
  • ✔ Annual General Meeting (AGM)
  • A Producer Company must hold 1 AGM every year.
  • Holding time:
  • 📅 Within 6 months of financial year end
  • 📅 Maximum gap allowed: 15 months between 2 AGMs

2️⃣ Board Meetings

  • ✔ Minimum 4 board meetings in a year
  • ✔ Gap between meetings: Max 120 days
  • ✔ Minutes must be recorded

3️⃣ Statutory Audit (Compulsory)

  • Producer Company must be audited every year by a Chartered Accountant.
  • Audit is compulsory even if:
  • ✔ No business
  • ✔ No profit
  • ✔ Farmer-based operations only

4️⃣ Income Tax Return (ITR-6)

  • All Producer Companies file ITR-6 (as they are treated like companies).
  • Audit is compulsory even if:
  • Due Dates:
  • • 📅 31 October → If accounts audited
  • • 📅 30 November → If Transfer Pricing applies

5️⃣ Special Compliances for Producer Companies

  • ✔ 1. Patronage Bonus Rules
  • If bonus/benefit is given to members → must follow Articles of Association.
  • ✔ 2. Limited Return (Dividend)
  • Producer Company can give limited return to members — rules must be followed.
  • ✔ 3. Transfer of Shares
  • Shares can be transferred only among producer members, not outsiders.
  • ✔ 4. Active Membership Check
  • Inactive members must be identified as per Articles.

6️⃣ ROC Event-Based Filings

  • These are required only when changes happen:
  • ✔ Change in directors → DIR-12
  • ✔ Change of registered office → INC-22
  • ✔ Increase in share capital → SH-7
  • ✔ Charge creation → CHG-1
  • ✔ Appointment of auditor → ADT-1

7️⃣ GST Compliances (If applicable)

  • If Producer Company sells:
  • • crops
  • • dairy
  • • handmade products
  • • processed farm goods
  • Then GST may apply.
  • ✔ File GSTR-1 & GSTR-3B
  • ✔ Issue GST invoice
  • ✔ Claim ITC if eligible
  • Some agricultural produce is exempt — must check classification.

8️⃣ TDS Compliances (If applicable)

  • If the company pays:
  • • Salaries
  • • Rent
  • • Professional fees
  • • Contractors
  • …it must:
  • ✔ Deduct TDS
  • ✔ Pay monthly
  • ✔ File quarterly TDS returns

9️⃣ Books & Records Maintenance

  • A Producer Company must maintain:
  • ✔ Cash book
  • ✔ Ledgers
  • ✔ Minutes book
  • ✔ Asset register
  • ✔ Member register
  • ✔ Patronage register
  • ✔ Invoices, vouchers & receipts
  • Good record-keeping = smooth audits

⭐ SUMMARY

Compliance
Required?
AOC-4
✔ Mandatory
MGT-7
✔ Mandatory
AGM
✔ 1 per year
Board Meetings
✔ 4 per year
Audit
✔ Compulsory
ITR-6
✔ Mandatory
GST/TDS
Only if applicable
Event Filings
When changes occur