Migration of MCA portal from Version 2 to Version 3
The Ministry of Corporate Affairs (MCA) had launched MCA 21 portal in 2006 to provide secure and easy access of MCA services for LLP’s and Companies i.e., from incorporation to closure and a platform to find all the details related to Companies & LLP’s. Therefore, it is mainly concerned with the administration, enforcement, and compliance of various legal requirements under the Companies Act, 1956, the Companies Act, 2013, LLP Act, 2008 and other allied laws.
MCA comes up with relevant changes and amendments of its portal from time to time for smooth functioning and administration. Until now, the V2 has been in place but very recently, the migration of e-forms from V2 to V3 is one of such amendments made to the MCA portal. LLP Services had been discontinued from 8th March 2022 on V2 portal and have been migrated to V3 portal. With effect from 10th January 2023, MCA rolled out/migrated the majority of e-forms related to Companies. To learn more about the e-forms that were migrated to V3 click here
The Version 3/ V3 is a new web-based portal and a completely updated version of the V2 portal. The main object of MCA 21 V3 is to provide professionals and stakeholders with reliable, smooth compliance, self-reporting and helpdesk portal with several new features and improvements. Furthermore, it aims to reduce the chances of error and omission in the e-forms as these modified e-forms seek for submission of additional disclosures. The major differences between the V2 and V3 are discussed below.
I.Key points of comparison between Version 2 (V2) vs. Version 3 (V3):
- Online e-form filings process – V2 portal requires the e-forms to be downloaded, filled, and then upload the same on portal, whereas in V3, the e-forms must be filled online over the portal and submitted online. This enables the user to save a half-filled e-form and file it later at his convenience.
- My Application feature – In V2 there was “My Workspace” feature which displays a list of notices and circulars issued by MCA. However, in V3 there is a personalised “My Application” feature which enables them to view all the e-forms filed by them till date along with their status viz, Approved, in progress, pending for DSC upload, Pay fees, resubmissions and download option which is available for limited time period.
- Login access through email ID – In V2 the user must create a specific user ID which cannot be an email ID and whereas in V3 by default the user ID will be CIN/LLPIN for corporates and email ID for professionals.
- OTP authentication – Every time the business user logs in to the MCA website from a different system and browser, an OTP will be sent to their mobile and email address given at the time of creating login credentials to ensure the authenticity of the user.
- Change in User Type – The user can be registered either as “Registered User” or “Business User”. Registered User has limited access to V3 portal whereas the Business Users can use all services under V3. The categories which are suitable for the company to register as a Business User are:
- Director/Designated Partner
- Manager/Secretary/Authorized Representative
- Officer in Default
However, “Professional User” which is a part of Business User in V3 was earlier termed as “Practicing Professional” in V2 portal.
II.Technical Glitches on V3 Portal:
The migration has been quiet challenging with every stakeholder facing various technical glitches on V3 portal. Here are the few instances of such technical errors.
a) While creating login credentials:
- While creating login credentials, the system displays an error stating that the given email ID is already linked to another user Id.
b) While logging in:
- When trying to login over V3 portal, it displays invalid password or invalid user ID. To resolve this issue if we click on forget password, no OTP is generated to the respective mobile number/ email ID.
- Even after entering the correct credentials there is a display stating that user ID and password doesn’t match.
c) Updating the profile of users:
- In case of any change in mobile number/email ID, and while trying to update the same on user profile page, the system shows the same page and does not respond.
d) While downloading the e-form:
- Unable to download the e-forms after entering all the details.
- Upon downloading the respective e-form, the DSC Box does not appear in the e-form for affixing the digital signature.
e) Other technical errors:
- Certification from professionals in e-forms was not required for small companies in V2. However, now in V3 certification from the professionals is shown as mandatory field.
- E-forms are not appearing in the Application history after submitting them successfully on the portal.
- After filing the e-forms, respective challans are not getting generated.
- Though the MCA has given relaxation with respect to paying additional fees till 21st February 2023, the system is displaying the filing fee including the additional fee charges.
III. Impact of technical glitches on Companies and LLP:
- Delay in the filing/compliances related to disclosure of private placements, rights issue, appointment of directors and creation of charge documents etc., as the V3 portal continues to face glitches, making uploading of e-forms difficult.
- Non filing of these e-forms might result the delay in fund infusion and/ utilization which can bring the entire businesses to a grinding halt.
- Due to the delay in filings, the Companies and LLPs are now expecting the possibility of auditor red-flags and fines.
IV. Actions taken by corporates, professionals, and other stakeholders:
- Various professional bodies have raised several tickets/complaints to the MCA officials expressing the issues faced by them.
- On several attempts of the repetitive action on trial-and-error base, the problem is being solved viz., able to login, download the e-form etc.,
V. Actions taken by the MCA officials to address the above issues:
- Ministry vide circular no. 04/2023 has relaxed the levy of additional fee for 46 company e-forms till 31st March 2023.
- MCA vide circular no. 05/2023 has given an option to file the following forms in physical mode from 22nd February 2023 to 31st March 2023 duly signed by the persons concerned as per the requirements of the relevant forms, along with a copy thereof in electronic media with the concerned registrar without payment of fee which has to be duly acknowledged.
However, the company has to give an undertaking stating that these forms will be filed in electronic form on MCA-21 Portal along with applicable fee upon smooth functioning of MCA V3 portal.
- The Finance and Corporate Affairs Minister Ms. Nirmala Sitharaman has directed officials to fix the problem expeditiously by forming a special team to address public grievances.
With the continuous efforts made by corporations, professionals, and other stakeholders, as well as MCA officials, it is hoped that all the issues will be resolved in the near future for smoothening of the filing process on the MCA Portal and thereby achieving the moto of ‘ease of doing business’.
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