CCFS 2026 Has Closed: From 1 October, Your Overdue AOC-4 Is Back to Rs 100 a Day (and the 90% Waiver Isn’t Returning)

On 30 September 2026, a two-lakh-rupee door quietly shut. CCFS 2026, the one-time window that let companies clear years of overdue ROC filings at just 10% of the late fee, reached the end of its final extension. From 1 October, a private company sitting on an unfiled AOC-4 is once again paying the full penalty: Rs 100 per day, per form, with no ceiling. A firm three years behind on both its financial statements and its annual return isn't looking at a discount any more. It's looking at a bill that can cross Rs 2 lakh, plus the return of a disqualification clock that CCFS had paused.

The window has shut, and most defaulting companies did not walk through it

For about five and a half months, the Ministry of Corporate Affairs handed non-compliant companies something rare: a way to come clean cheaply. The Companies Compliance Facilitation Scheme, 2026, let a company with pending statutory filings pay the normal filing fee plus only 10% of the accumulated additional fee. That is a 90% cut on the part of the bill that hurts most.

The scheme was aimed squarely at a specific pain. Thousands of small and mid-sized private companies still carry backlogs from the COVID years and the messy MCA-21 V3 migration of 2022-23. Many of these are companies with revenue between Rs 5 crore and Rs 500 crore that simply lost track of a year, changed auditors, or assumed a dormant subsidiary didn't need filing. For them, CCFS 2026 was the cheapest exit from a growing liability they had ever been offered.

The problem: a scheme only helps the companies that act inside it. Plenty didn't. Some never knew it existed. Some kept waiting for "one more extension" and ran out of extensions. From 1 October 2026, those companies are back in the full-fee regime, and the arithmetic is unforgiving.

Diagram 1: What the same overdue filing costs before and after the window

The table below shows the practical gap for a company that is roughly two years late on its annual filings. The normal filing fee depends on authorised capital; the figures below use an illustrative normal fee of Rs 400 per form to show the mechanics. Your actual normal fee and days of delay will change the rupee amount, so treat this as the shape of the problem, not a quote.

Two years is a conservative example. Companies carrying four or five years of backlog were the scheme's real target, and for them the gap between the 10% figure and the full figure ran into lakhs.

How CCFS 2026 rose and fell: the circular trail

The scheme was never open-ended, though three extensions made it feel that way. Here is the actual sequence, straight from the MCA general circulars.

ICSI had asked the Ministry for a one-time extension into late September, which is part of why so many companies waited. The lesson for the next scheme is blunt: an extension you are counting on is not an extension you have. File on the date in front of you, not the date you hope for.

What CCFS covered, and what it never did

The scheme applied to ten Companies Act, 2013 e-forms and their legacy 1956 equivalents: MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), AOC-4 XBRL, ADT-1, FC-3 and FC-4. It also gave a discount on the two exit routes: MSC-1 for dormant status at half fee, and STK-2 for strike-off at a quarter of the fee.

It left several groups out. LLPs were never covered; a separate regime applies to them. Companies that had already received a final strike-off notice under Section 248, companies that had already filed STK-2 or MSC-1, and companies flagged as vanishing were all excluded. So were charge-related forms such as CHG-1. If your default sat outside the covered list, CCFS was never your route, and nothing about its closure changes your position.

Diagram 2: The numbers that should worry a defaulting board

The penalty you can see, and the one you can't

There are two separate consequences of a late filing, and defaulting companies usually only think about the first.

The visible one is the additional fee. For AOC-4 and MGT-7/7A, this is a flat Rs 100 per day per form with no upper limit, levied automatically at the payment stage on MCA-21 V3 under Section 403. For most other forms, the additional fee follows a slab: up to 30 days of delay costs 2x the normal fee, up to 60 days 4x, up to 90 days 6x, up to 180 days 10x, and beyond 180 days a full 12x. This is money you pay just to upload the form. CCFS knocked 90% off it. That 90% is gone.

The one companies miss is the penalty under adjudication. Filing late does not erase the offence. Under Section 92(5), a company that files its annual return late, and every officer in default, can be penalised Rs 10,000 plus Rs 100 for each day of continuing default, up to Rs 2 lakh for the company and Rs 50,000 for each officer. Section 137(3) mirrors this for financial statements. The Registrar can issue an adjudication notice under Section 454 even after you have paid the additional fee and filed. The additional fee buys you the filing. It does not buy you out of the offence.

Behind both sits the consequence that ends careers, not just budgets. Under Section 164(2), if a company fails to file its financial statements or annual returns for three continuous financial years, every director of that company is disqualified. Their DIN is deactivated, and they are barred from every board they sit on for five years. Filing even one pending year under CCFS broke that chain. For a company that did not file, the three-year count is simply running again from wherever it stood.

What you must do now

The window is closed, but the situation is not hopeless. It is just more expensive than it was last week. Work through these in order.

1. File the oldest overdue AOC-4 or MGT-7 first, today. The Rs 100/day charge is uncapped and it does not pause while you plan. The single most useful thing a defaulting company can do this week is stop the daily bleed on its most-delayed form. Run the numbers before you file so there are no surprises at the payment screen. Our MCA Penalty Calculator gives you the additional fee for each form based on its days of delay.

2. Reconstruct the paperwork the forms depend on. AOC-4 needs adopted financial statements and a board report; MGT-7 needs a completed annual return; ADT-1 needs a valid auditor appointment. If your auditor appointment itself was never filed, fix that first, because a late AOC-4 built on a shaky auditor position invites a second problem.

3. If the company is genuinely inactive, choose an exit rather than a permanent drip. A company that is not trading does not need to keep paying Rs 100 a day forever. You can move it to dormant status under Section 455 using MSC-1, or apply for strike-off using STK-2. Both now cost the full fee rather than the CCFS discount, but they cap your future exposure. Our guide on dormant status and strike-off walks through which route fits which company.

4. Use Section 460 condonation where a genuine reason exists. For certain delays, the Central Government can condone the delay under Section 460. This is a discretionary relief, not a fee waiver, and it is granted on the strength of the reason you give: illness, records lost in the V3 migration, a bona fide dispute over the accounts. It will not rescue a company that simply ignored its filings, but for a defensible delay it is worth a properly drafted application.

5. If you have already been struck off, appeal under Section 252. Where the Registrar has removed the company's name, a Section 252 appeal to the NCLT can restore it, usually within three years of the strike-off order, on the condition that all pending returns are filed and costs are paid. This is the most expensive path of all, which is exactly why steps one to three matter.

One more point for smaller companies: under Section 446B, a small company, a One Person Company, a startup or a producer company pays half the adjudication penalty, subject to a cap. It does not reduce the additional fee, but it softens the Section 454 penalty if a notice arrives.

The deeper implication

According to CS Sapna Malpani, the closure of CCFS 2026 marks a shift in how the Ministry is likely to treat backlogs. Three amnesties in eighteen months, from the earlier condonation schemes to CCFS, trained a section of the market to wait for the next discount instead of filing on time. A cheap regularisation route, offered often enough, stops being relief and starts being a reason to default. The pattern from the Ministry's own adjudication data is that once a scheme lapses, the Registrar's offices move from facilitation to enforcement: adjudication notices under Section 454, strike-off drives under Section 248, and closer scrutiny of directors sitting on multiple defaulting companies.

The forward view is straightforward. Companies that treated CCFS as their safety net should assume the net has been taken down and that the next twelve months will be about enforcement, not amnesty. The prudent move is to close every open filing now, at full fee if necessary, rather than bank on a scheme that may not come, and that may not cover your form even if it does.

How CCFS relief compares with the reliefs that remain

It helps to see where each option sits, because they are often confused.

CCFS 2026 was a fee concession: file the same form, pay 10% of the late fee. It applied automatically to a fixed list of forms and asked no questions about why you were late. That route has closed. Section 460 condonation is not about fee at all: it is the Central Government excusing the delay itself, granted case by case on the reason shown. Section 454 adjudication runs in the other direction: it is the process by which a penalty is imposed on you for the default, and your role there is to respond to a notice and argue for the minimum. And Section 446B is not a route you apply for but a statutory discount that halves the adjudication penalty for small companies and startups. Knowing which lever you are pulling, whether a fee, an excuse, a defence, or a statutory cap, keeps you from asking the wrong office for the wrong thing.

Sources and references

• MCA General Circular No. 01/2026 dated 24 February 2026, Companies Compliance Facilitation Scheme, 2026: mca.gov.in
• MCA General Circular No. 03/2026 dated 08 July 2026, extension to 31 August 2026: mca.gov.in
• MCA General Circular No. 04/2026 dated 31 August 2026, extension to 15 September 2026: mca.gov.in
• Section 403, Companies Act, 2013, Fee for filing, and Companies (Registration Offices and Fees) Rules, 2014: indiacode.nic.in
• Sections 92(5) and 137(3), Companies Act, 2013, penalties for late annual return and financial statements: indiacode.nic.in
• Section 164(2), Companies Act, 2013, director disqualification for continuous default: indiacode.nic.in
• Sections 446B, 454, 455, 460 and 252, Companies Act, 2013: indiacode.nic.in

Frequently asked questions

Is CCFS 2026 still open in October 2026?

No. CCFS 2026 ran from 15 April 2026 and, after two further extensions through General Circulars 03/2026 and 04/2026, its window lapsed at the end of September 2026. As of October 2026 no fresh amnesty has been notified, and the 90% additional-fee concession is no longer available. Any overdue form you file now attracts the full additional fee under Section 403. If the Ministry announces a new scheme later, it will come through a fresh general circular; until then, assume full fees apply.

What does a late AOC-4 or MGT-7 cost now that CCFS 2026 has closed?

For AOC-4 and MGT-7/7A, the additional fee is a flat Rs 100 per day per form with no upper limit, charged automatically when you upload the form on MCA-21 V3. A form two years overdue therefore carries roughly Rs 73,000 in additional fee on its own, before any separate penalty. This is the charge CCFS 2026 had reduced to 10%. With the scheme closed, you pay the full amount, which is why filing the oldest form first matters, because the clock does not stop while you wait.

I missed the CCFS 2026 deadline. Can I still regularise my company?

Yes. Missing CCFS 2026 makes regularisation costlier, not impossible. File your overdue AOC-4, MGT-7 and ADT-1 at the full additional fee to bring records current. If the company is inactive, move it to dormant status under Section 455 (MSC-1) or apply for strike-off (STK-2). Where a genuine reason for delay exists, a Section 460 condonation application to the Central Government may help. The route depends on whether the company intends to keep trading or wind down.

Can I still be penalised after paying the additional fee?

Yes. The additional fee under Section 403 lets you upload the form, but it does not extinguish the offence of late filing. The Registrar can separately adjudicate a penalty under Section 454. For a late annual return, Section 92(5) allows a penalty of Rs 10,000 plus Rs 100 per day of continuing default, up to Rs 2 lakh for the company and Rs 50,000 for each officer in default; Section 137(3) is similar for financial statements. Small companies, OPCs and startups pay half the penalty under Section 446B, subject to a cap.

Does missing CCFS 2026 affect director disqualification?

It can. Under Section 164(2), if a company fails to file its financial statements or annual returns for three continuous financial years, every one of its directors is disqualified and their DIN is deactivated for five years, across all companies they serve. Filing even one pending year under CCFS broke this chain. A company that did not use the scheme simply continues counting toward the three-year mark, so clearing at least the most recent defaults promptly is the way to protect the board.

Were LLPs covered under CCFS 2026?

No. CCFS 2026 applied to companies under the Companies Act, 2013 and covered a fixed list of company e-forms such as MGT-7, AOC-4, ADT-1, FC-3 and FC-4. LLPs fall under the LLP Act and were outside the scheme. LLPs with overdue Form 8 or Form 11 have their own deadlines and their own penalty structure of Rs 100 per day, and should track those separately rather than assume any company-side amnesty applied to them.