A private limited company in Mumbai discovered last month that it owed ₹3,28,500 in late filing penalties to the MCA — for just three years of missed annual returns and financial statements. At ₹100 per day, per form, with no upper cap, the penalties had been silently compounding while the founders focused on growing their business.
That company now has a lifeline. Starting 15th April 2026 — just days from now — the Ministry of Corporate Affairs is opening a 90% penalty waiver window under the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). That ₹3,28,500 penalty? It drops to approximately ₹32,850 under the scheme.
But this window closes on 15th July 2026. Miss it, and there is no guarantee the MCA will offer anything like this again.
What Is CCFS-2026?
The Companies Compliance Facilitation Scheme, 2026 was introduced by the MCA through General Circular No. 01/2026 dated 24th February 2026, exercising powers under Section 460 read with Section 403 of the Companies Act, 2013.
In plain terms, it is a one-time amnesty window that allows companies with pending ROC filings to clear their backlog by paying only 10% of the additional fees that would otherwise apply. The scheme is operational from 15th April 2026 to 15th July 2026 — a three-month window.
This is not the first such scheme. The MCA ran the Company Fresh Start Scheme (CFSS) in 2020 and the Condonation of Delay Scheme (CODS) before that. However, there is a notable shift this time. The name change from “Settlement Scheme” to “Compliance Facilitation Scheme” signals the MCA’s intent: this is about cleaning the company registry, not just forgiving defaults. Companies that do not come forward during this window may face stricter enforcement afterward, including accelerated strike-off proceedings under Section 248.
Who Can Use This Scheme?
Almost every company registered in India that has pending annual filings can benefit. This includes private limited companies, one person companies, Section 8 companies, and even foreign companies registered in India.
However, the following companies are excluded:
- Companies against which a final notice for strike-off under Section 248 has already been issued
- Companies that have already filed a strike-off application (STK-2) before the scheme
- Companies that applied for dormant status under Section 455 before the scheme
- Companies dissolved through amalgamation or court orders
- “Vanishing companies” as identified by the MCA
What Forms Are Covered?
CCFS-2026 covers the critical annual compliance forms that most companies default on:
- Financial Statements: Form AOC-4, AOC-4 XBRL, AOC-4 CFS, AOC-4 NBFC (and legacy forms 23AC/23ACA)
- Annual Returns: Form MGT-7 and MGT-7A (and legacy forms 20B/21A)
- Auditor Appointment: Form ADT-1 (and legacy form 23B)
- Foreign Company Filings: Forms FC-3 and FC-4
If your company has missed filing any of these forms for one year or for ten years, this scheme applies to all pending filings.
The Real Numbers: How Much Do You Save?
Let us break this down with a realistic example that many private limited companies in India will recognise.
Scenario: A private limited company has not filed its AOC-4 and MGT-7 for three financial years (FY 2022-23, FY 2023-24, and FY 2024-25).
Normal penalty calculation:
The MCA levies additional fees of ₹100 per day of delay for each form. Assuming an average delay of approximately 365 days per year of default, the calculation works out as follows:
- AOC-4 (3 years): 1,095 days × ₹100 = ₹1,09,500
- MGT-7 (3 years): 1,095 days × ₹100 = ₹1,09,500
- Total additional fees: ₹2,19,000
Under CCFS-2026:
- You pay only 10% of the additional fees: ₹2,19,000 × 10% = ₹21,900
- Total savings: ₹1,97,100
For companies with five or more years of defaults, the savings can run into lakhs. One company secretary professional reported a client with seven years of pending filings facing ₹5,11,000 in additional fees — reduced to ₹51,100 under the scheme.
Three Pathways Under CCFS-2026
The scheme does not just help companies that want to continue operating. It also provides structured exits for companies that have no business activity.
Pathway 1 — Regularise and Continue: File all pending annual returns and financial statements by paying 10% additional fees. Your company returns to active, compliant status on the MCA portal. This is the right choice for operating companies that fell behind on paperwork.
Pathway 2 — Apply for Dormant Status: If your company has no significant accounting transactions for two financial years, you can file Form MSC-1 to obtain dormant status under Section 455. Under CCFS-2026, you pay only 50% of the normal MSC-1 filing fee. Dormant companies maintain their legal existence but have reduced compliance requirements.
Pathway 3 — Voluntary Strike-Off: If your company is truly defunct and you want to close it permanently, you can file Form STK-2 for voluntary strike-off at just 25% of the standard filing fee — that is ₹2,500 instead of ₹10,000. This is the cleanest and cheapest exit route available for companies with no assets or liabilities.
What You Must Do Now: A 7-Step Action Plan
Step 1 — Check Your MCA Status Today: Log in to the MCA V3 portal and check your company’s compliance status. Identify all pending forms — AOC-4, MGT-7, MGT-7A, and ADT-1 for each defaulting year.
Step 2 — Verify You Are Not Excluded: Confirm that no strike-off notice under Section 248 has been issued against your company. Check if your company’s status shows “Active” or “Active-Default” on the MCA portal — both are eligible. “Struck Off” companies are not eligible.
Step 3 — Gather Your Financial Records: Collect audited financial statements, board resolutions, and director KYC documents for all pending years. If your books are not up to date, engage an auditor immediately — the three-month window is tighter than it appears.
Step 4 — Complete DIR-3 KYC for All Directors: Before filing annual returns, ensure every director’s KYC is current. A deactivated DIN will block your filings, and the reactivation itself costs ₹5,000 per director.
Step 5 — File ADT-1 First: If your company has not filed the auditor appointment notice, file Form ADT-1 first. Many companies overlook this, and it is a prerequisite for filing financial statements.
Step 6 — File AOC-4, Then MGT-7 in Sequence: Financial statements (AOC-4) must be filed before annual returns (MGT-7) for each financial year. File them in chronological order — oldest year first.
Step 7 — Engage a Practising Company Secretary: A qualified CS can calculate your exact fee liability under CCFS-2026, ensure the correct filing sequence, and handle the MCA portal submissions. Given that the scheme window is limited and MCA portal congestion is expected in June-July, acting in April gives you the best chance of smooth filings.
The Deeper Implication: Why This Scheme Signals Stricter Enforcement Ahead
The MCA does not launch amnesty schemes out of generosity. Every previous compliance window — CFSS 2020, CODS 2018 — was followed by a crackdown. After CFSS 2020, the MCA initiated strike-off proceedings against over 2.26 lakh companies in a single year.
The naming shift to “Compliance Facilitation Scheme” is deliberate. The MCA is cleaning its registry. Companies that do not regularise during this window will likely face accelerated enforcement: strike-off notices under Section 248, director disqualification proceedings under Section 164(2), and adjudication penalties under Sections 92 and 137.
For directors, the personal stakes are real. Under Section 164(2)(a), if a company fails to file its annual return or financial statements for three consecutive years, every director of that company at the time of default becomes disqualified from being appointed as a director in any company for a period of five years. This disqualification carries forward even if you resign from the defaulting company.
CCFS-2026 is your last clear exit before enforcement tightens. Treat it accordingly.
Key Takeaways
- CCFS-2026 runs from 15th April to 15th July 2026 — a three-month window that starts in days
- Companies save 90% on late filing penalties by paying only 10% of additional fees
- The scheme covers AOC-4, MGT-7, MGT-7A, ADT-1, and foreign company filings
- Three pathways are available: regularise (10% fees), go dormant (50% MSC-1 fee), or strike off (25% STK-2 fee)
- Companies excluded from a final strike-off notice cannot apply
- Director disqualification under Section 164(2) is a real and personal consequence of continued non-compliance
- Post-scheme enforcement is expected to be significantly stricter based on MCA’s historical pattern
Sources
- MCA General Circular No. 01/2026 dated 24th February 2026
- Section 403, 455, 460 of the Companies Act, 2013
- Companies (Registration Offices and Fees) Rules, 2014
- Taxmann Analysis: CCFS 2026 — MCA Scheme to Clear Pending Company Filings
- ICSI Practice Advisory on CCFS-2026
Frequently Asked Questions
Can a company that has been marked as “Active-Default” on MCA use CCFS-2026?
Yes. Companies with “Active” or “Active-Default” status are eligible for CCFS-2026. The scheme is specifically designed for companies in default. The only exclusion is for companies against which a final strike-off notice under Section 248 has been issued, companies already dissolved, or “vanishing companies.” If your company shows “Active-Default,” this scheme is precisely what you need.
What happens if I file some forms under CCFS-2026 but miss the deadline for others?
The 10% additional fee benefit applies only to forms filed within the scheme window (15th April to 15th July 2026). Any forms filed after 15th July will attract the full additional fee of ₹100 per day. There is no partial extension. This is why engaging a Company Secretary early in April is critical — it gives you the full three months to prepare and file all pending documents in the correct sequence.
Will filing under CCFS-2026 remove the director disqualification under Section 164(2)?
Filing pending returns under CCFS-2026 does not automatically reverse an existing disqualification. However, it stops the default from continuing, which is the trigger for disqualification. If disqualification proceedings have not yet been initiated, timely filing under the scheme effectively prevents them. If a director is already disqualified, they may need to approach the NCLT under Section 164(3) for relief. Regularising the company’s filings strengthens that application significantly.
Is there any immunity from prosecution under CCFS-2026?
Yes, with conditions. Companies that file their pending documents under the scheme before any adjudication notice is issued, or within 30 days of receiving such notice, receive immunity from penalty proceedings under Sections 92 and 137 of the Companies Act. However, penalties already imposed through adjudication orders before the scheme remain payable. The scheme offers prospective relief, not retrospective cancellation of confirmed penalties.
My company has no business activity. Should I regularise or apply for strike-off under CCFS-2026?
If your company has no assets, no liabilities, and no intention of future operations, the strike-off pathway at 25% of STK-2 fees (approximately ₹2,500) is the most cost-effective exit. If you may want to revive the company later, applying for dormant status at 50% of MSC-1 fees preserves the company’s legal existence while reducing ongoing compliance requirements. A Practising Company Secretary can help you evaluate which pathway makes the most financial and strategic sense for your specific situation.
Do Not Wait Until July
The CCFS-2026 window opens on 15th April and closes on 15th July 2026. History shows that MCA portal congestion peaks in the final weeks of every compliance scheme. If you have pending filings, start now.
Use the Annual Compliance Checker on sapnamalpani.com to assess your company’s filing status, or book a consultation with CS Sapna Malpani to get a personalised CCFS-2026 action plan for your company.