DIR-3 KYC: the filing that suspends a director’s DIN

A Director Identification Number is issued once and lasts a lifetime, but it only stays usable if the person behind it confirms every so often that they still exist and their details are current. That confirmation is DIR-3 KYC.

The obligation sits on the individual, not the company. This catches people out constantly: a founder assumes the company secretary handles “the filings”, and nobody files the KYC for a director who joined years ago and rarely thinks about the board. The company can be perfectly compliant while one of its directors quietly loses the ability to act as one.

The rhythm changed recently. Rule 12A of the Companies (Appointment and Qualification of Directors) Rules was substituted by G.S.R. 943(E) dated 31 December 2025, moving DIR-3 KYC from an annual filing to a three-yearly one, still due by 30 June. Fewer filings, but a longer gap in which to forget — and the consequence is unchanged.

That consequence is not a late fee that grows quietly. The DIN is deactivated. A deactivated DIN cannot be used to sign a board resolution, a financial statement, or any form filed with the ROC. If that director is one of only two on a small board, ordinary business stops until the KYC is filed and the reactivation fee is paid.

The fix is unexciting: know every DIN attached to your company, know when each one is next due, and treat it as the individual’s obligation that the company happens to track.