ICSI Flags Persistent MCA-21 V3 Portal Deficiencies, Urges Ministry to Prioritize Technical Overhaul

Background and Context

The Institute of Company Secretaries of India (ICSI) has formally written to the Ministry of Corporate Affairs (MCA), drawing attention to a range of unresolved technical and operational difficulties being experienced by stakeholders on the MCA-21 V3 portal. The representation, dated 6th May 2026, was addressed to Ms. Deepti Gaur Mukerjee, Secretary, Ministry of Corporate Affairs, and was submitted under reference G&CL: MCA: MAY:2026.

While the ICSI acknowledged the Ministry's commendable strides in advancing digital governance and streamlining corporate compliance, it underscored that the current state of the portal is generating avoidable inefficiencies, duplication of effort, and unintended defaults — outcomes that are directly contrary to the ease-of-doing-business objectives the MCA-21 V3 initiative was designed to serve.

The representation reflects the collective experience of ICSI members and other stakeholders who interact with the MCA portal on a daily basis for statutory filings and compliance purposes.


Key Technical and Functional Problems Identified

The ICSI representation systematically catalogued the issues under distinct heads, each accompanied by a practical recommendation. The following is a structured breakdown of the concerns raised.


1. Loss of Saved Drafts and Absence of Reliable Auto-Save Functionality

One of the most frequently reported grievances relates to the inability to reliably retrieve saved drafts. Stakeholders have reported losing data mid-work due to session timeouts, which force them to restart the entire form-filling process from scratch. This is particularly problematic for complex filings that require significant time and multiple rounds of review.

Impact:

  • Loss of partially completed work
  • Increased time and resource consumption
  • Greater probability of data entry errors during re-filling

ICSI's Recommendation:

The ICSI has proposed the introduction of a robust draft management system equipped with an auto-save feature, enabling users to resume work from the point of interruption without data loss. This is a standard feature in most modern digital filing environments and its absence on the MCA-21 V3 portal represents a significant usability gap.


2. Attachment Upload Failures

Stakeholders have consistently flagged failures in uploading attachments to e-forms. The causes identified include overly restrictive file-size limits, format incompatibilities, and intermittent system glitches. In many instances, documents that are otherwise complete and properly formatted are being rejected by the portal without clear error communication.

Impact:

  • Filing delays and missed deadlines
  • Repeated upload attempts causing frustration and loss of productivity
  • Risk of non-compliance due to incomplete submissions

ICSI's Recommendation:

The ICSI has called for an increase in the permissible attachment size limit to ensure that filings remain legible and complete. Additionally, system-level improvements are needed to address the underlying glitches causing upload rejections.


3. Login Errors and Dysfunctional "Switch User" Feature