CCFS 2026: Save 90% on MCA Penalties – The Complete Guide to the ROC Filing Amnesty Window (15 April – 15 July 2026)
Last updated: 22 April 2026 | By CS Sapna Malpani, Practising Company Secretary, Bangalore
A Bangalore-based private limited company with two years of missed annual filings walked into our office last week. The standard additional fee quote from the MCA V3 portal: ₹1,33,600. After applying the Companies Compliance Facilitation Scheme, 2026 (CCFS 2026), the final bill came to ₹13,360 – a straight saving of ₹1,20,240 on a single filing session. That is what this scheme is doing for thousands of defaulting companies across India right now. The window closes on 15 July 2026, and no extension has been notified.
Quick Summary
Scheme name: Companies Compliance Facilitation Scheme, 2026 (CCFS 2026)
Authority: MCA General Circular No. 01/2026 dated 24 February 2026
Window: 15 April 2026 to 15 July 2026 (84 days remaining as of today)
Who must act: Every private limited, public unlisted, Section 8 and foreign company with overdue MGT-7, AOC-4, ADT-1, FC-3, FC-4 or legacy 1956 Act forms
Benefit: Pay only 10% of the additional filing fees (90% waiver) plus immunity from Section 92/137 adjudication penalties if filed before ROC notice or within 30 days of notice
Key action: Audit backlog now. File all eligible forms by 15 July 2026.
Time to act: Board meeting backfill + AGM adoption + MCA V3 upload typically takes 4-6 weeks. Cutting it fine past mid-June is risky.
Why CCFS 2026 Is a Once-in-a-Cycle Opportunity
Amnesty schemes from the Ministry of Corporate Affairs are rare. The last comparable window was the Companies Fresh Start Scheme (CFSS) in 2020, triggered by the pandemic. Before that, the Condonation of Delay Scheme (CODS) in 2018. The gap between meaningful amnesties has stretched to 5-6 years on average. The next one is not scheduled, and based on MCA’s recent enforcement tone, it will not come soon.
Over the last 18 months, Registrars of Companies have issued adjudication orders at a pace not seen before. Our firm tracks MCA orders weekly. In FY 2025-26 alone, over 4,800 adjudication orders crossed our desk – many for simple filing defaults that the company secretary could have flagged if someone was watching. Typical penalty slabs for a single year’s default on MGT-7 or AOC-4 now range from ₹1 lakh to ₹11 lakh per company, plus ₹50,000 on each director. CCFS 2026 wipes out most of that exposure for companies that act in time.
The scheme also protects against the silent killer: Section 164(2) director disqualification. Three consecutive years of non-filing of MGT-7 or AOC-4 triggers automatic director disqualification for five years across all companies. Many founders discover this only when their next fundraise or board appointment fails a compliance check. Clearing the backlog under CCFS 2026 stops the Section 164(2) clock before it strikes.
VISUAL: Fee Waiver Matrix – What CCFS 2026 Actually Gives You
| Form Category | Forms Covered | Normal Regime | CCFS 2026 Pays | Effective Waiver |
|---|---|---|---|---|
| Annual Returns | MGT-7, MGT-7A | Up to 12x base fee | 10% of additional fee | 90% |
| Financial Statements | AOC-4, AOC-4 CFS, AOC-4 NBFC | Up to 12x base fee | 10% of additional fee | 90% |
| Auditor Appointment | ADT-1 | Up to 12x base fee | 10% of additional fee | 90% |
| Foreign Companies | FC-3, FC-4 | Up to 12x base fee | 10% of additional fee | 90% |
| Legacy 1956 Act Forms | 20B, 21A, 23AC, 23ACA, 66, 23B | Maximum slab | 10% of additional fee | 90% |
| Dormant Application | MSC-1 | Full normal fee | 50% of normal fee | 50% |
| Voluntary Strike-off | STK-2 | Full normal fee | 25% of normal fee | 75% |
Source: MCA General Circular No. 01/2026 dated 24 February 2026 read with the Companies (Registration Offices and Fees) Rules, 2014.
Who Can Use CCFS 2026 – and Who Is Shut Out
Eligible
- Private limited companies with overdue MGT-7 / MGT-7A or AOC-4 filings for any financial year
- Public unlisted companies with pending annual return or financial statement filings
- Section 8 companies behind on ROC filings
- Foreign companies that have missed FC-3 / FC-4 filings
- Any company with legacy 1956 Act forms (20B, 21A, 23AC, 23ACA, 66, 23B) still pending
- Active companies that want to voluntarily move to dormant status via MSC-1
- Defunct companies that want to exit via STK-2 at a reduced fee
Ineligible (Hard Block)
- Companies already facing strike-off action under Section 248 where the final notice has been issued by the ROC
- Companies that have themselves filed an STK-2 strike-off application before 15 April 2026
- Companies already holding dormant status (application filed before scheme inception)
- Companies dissolved via amalgamation or demerger
- Companies classified as “vanishing companies” by MCA
VISUAL: The Real Cost of Missing the Window
| Default Provision | Company Penalty | Officer Penalty | Continuing Default |
|---|---|---|---|
| Section 92(5) – Non-filing of annual return | ₹10,000 minimum, up to ₹2 lakh | ₹10,000 minimum, up to ₹50,000 | ₹100 per day each |
| Section 137(3) – Non-filing of financial statement | ₹10,000 minimum, up to ₹2 lakh | ₹10,000 minimum, up to ₹50,000 | ₹100 per day each |
| Section 164(2) – Director disqualification | 5-year disqualification across all companies after 3 consecutive years of default | ||
| Section 248 – Strike-off | Company removed from Register; reinstatement needs NCLT order plus costs | ||
Source: Companies Act, 2013, read with the Companies (Adjudication of Penalties) Rules, 2014.
A Worked Example: ₹1.2 Lakh Saved in One Afternoon
Consider a typical Bangalore private limited company with paid-up capital of ₹25 lakh. The company missed filings for FY 2023-24 (due by October 2024) and FY 2024-25 (due by October 2025). Today is 22 April 2026, which means both years are significantly delayed.
⚡ Savings Illustration – Two Years of Missed Filings
Standard additional fee (both years, all forms)
CCFS 2026 additional fee
Actual saving
Discount on additional fee
Plus immunity from Section 92/137 adjudication penalty (potentially ₹5 lakh more).
| Form | Year | Days Delayed | Normal Fee | CCFS 2026 Fee | Saved |
|---|---|---|---|---|---|
| AOC-4 | FY 23-24 | ~540 | ₹53,200 | ₹5,320 | ₹47,880 |
| MGT-7 | FY 23-24 | ~510 | ₹50,100 | ₹5,010 | ₹45,090 |
| AOC-4 | FY 24-25 | ~175 | ₹16,700 | ₹1,670 | ₹15,030 |
| MGT-7 | FY 24-25 | ~145 | ₹13,600 | ₹1,360 | ₹12,240 |
| Total | ₹1,33,600 | ₹13,360 | ₹1,20,240 | ||
Illustrative figures based on indicative fee slabs under the Companies (Registration Offices and Fees) Rules, 2014. Actual additional fee depends on the authorised capital slab and delay duration per the MCA portal calculator.
VISUAL: The Compliance Timeline You Need to Hit
15 April 2026 – Scheme opens on MCA V3. Fee auto-calculates at 10% of additional fee slab.
22 April 2026 (today) – 84 days remaining. Ideal point to start: full internal audit + board meetings + AGM cycle + filing.
15 June 2026 – 30 days before close. Last safe date to start the process for most companies. Beyond this, document preparation + board meeting calendar gets tight.
15 July 2026 – Scheme closes. All forms must be approved (not just uploaded) by this date. Normal regime resumes immediately.
After 15 July 2026 – ROCs expected to accelerate adjudication under Section 454. Companies that skipped the amnesty become priority targets.
Step-by-Step: How to File Under CCFS 2026
The scheme does not have a separate application form or approval workflow. The relief is baked into the MCA V3 portal’s fee calculator for the scheme window. The compliance heavy lifting happens inside the company’s books and minutes.
Step 1 – Run a ROC Compliance Audit
Log into MCA V3. Under “View Signatory Details” and “View Public Documents”, pull a complete history of past filings for every financial year since incorporation or the last filed year. Identify every missed MGT-7 / MGT-7A, AOC-4 (and variants), ADT-1, FC-3 / FC-4. If you incorporated before 2014, check for the six legacy 1956 Act forms as well. Our firm does this audit free for any company that signs up for the scheme window – reach out via the contact link below.
Step 2 – Verify Eligibility
Confirm none of the five ineligibility flags apply: Section 248 strike-off notice issued, STK-2 already filed, dormant status already held, company dissolved by amalgamation, or classification as a vanishing company. One easy check: search for the CIN on the “View Public Documents” section and look for any STK-5 or strike-off notice issued by the ROC.
Step 3 – Backfill Board Meetings and Resolutions
For each missed year, pass board resolutions to: approve the financial statements, approve the directors’ report, approve the auditor’s report, authorise signing of MGT-7 and AOC-4, and file MGT-14 where any of the approved matters triggers Section 117 requirements. Compile minute books, notices, and attendance sheets. This is where the engagement of a practising company secretary pays for itself – board meetings held out of time must be documented carefully to withstand scrutiny.
Step 4 – Hold the AGMs
Section 96 requires an AGM for every financial year. For missed years, convene an adjourned AGM or a fresh AGM (as permissible under law and the articles). Adopt the accounts. Capture the minutes and ordinary resolutions.
Step 5 – Upload Forms on MCA V3
File in chronological order: oldest year first. For each year, file AOC-4 first, then MGT-7 (or MGT-7A for small companies). ADT-1 for any auditor appointment not already reported. The portal will show reduced fees during the scheme window – verify that the fee is indeed 10% of the additional fee slab before paying.
Step 6 – Pay and Preserve Records
Pay via MCA’s online gateway. Download every challan, SRN acknowledgement, and approved form. Save copies in the company’s permanent filing folder. Keep a reconciliation sheet showing the normal fee, CCFS 2026 fee, and savings.
Step 7 – File Before the Window Closes
The form must be approved by the ROC (not just uploaded) by 15 July 2026. Given that some forms go into “Under Processing” status for 3-5 days, aim to have everything submitted by 30 June 2026 at the outside. Do not wait until the last week.
The Deeper Implication: MCA Is Clearing the Decks Before a Stricter Regime
According to CS Sapna Malpani, “CCFS 2026 is not a gift from the MCA – it is a strategic reset. The Ministry wants to close the backlog of defaulting companies either by getting them compliant (amnesty), dormant (MSC-1 at 50%), or struck off (STK-2 at 25%). Once this scheme ends on 15 July 2026, expect a sharp rise in Section 454 adjudication orders, director disqualifications under Section 164(2), and Section 248 strike-offs. Companies that ignore this window are signing up for much harder conversations in Q3 and Q4 of 2026.”
The MCA’s data-analytics muscle has grown considerably. V3 portal logs, GSTN cross-referencing, and the new Central Processing Centre (CPC) at IICA give the Ministry clear visibility into which CINs are dormant-but-active. Enforcement post-amnesty is therefore not a threat – it is a certainty. Companies with overdue filings who skip CCFS 2026 should treat adjudication notices as a matter of when, not if.
How CCFS 2026 Differs from Related Compliance Reliefs
Founders often confuse CCFS 2026 with other reliefs. It is narrower than it looks and broader in effect only for certain form categories.
| Feature | CCFS 2026 | CFSS 2020 | Condonation (Sec 460) |
|---|---|---|---|
| Fee relief | 90% on additional fee | 100% waiver | Case-by-case |
| Forms covered | 11 specific forms | All belated forms | All forms |
| Immunity | Sec 92/137 only | Broad immunity | Only delay condoned |
| Application form | Auto via MCA V3 | Form CFSS separately | Application to RD/CG |
| Window | 3 months | 9 months | No time bar |
Note that CCFS 2026 does NOT cover DPT-3, DIR-3 KYC, MSME Form 1, INC-22A, BEN-2, INC-20A, or PAS-6. These forms continue under their normal additional fee and adjudication regimes. A company that wants full compliance often needs both CCFS 2026 for the annual return / financial statement backlog AND ordinary filings (with full additional fees) for the other pending forms.
Key Takeaways
📋 What to Remember
- ✅ CCFS 2026 runs from 15 April to 15 July 2026 – a one-time three-month window notified by MCA General Circular No. 01/2026.
- ✅ Pay only 10% of the additional filing fees on MGT-7, MGT-7A, AOC-4, AOC-4 CFS, AOC-4 NBFC, ADT-1, FC-3, FC-4 and six legacy 1956 Act forms.
- ✅ Companies with two years of missed annual filings commonly save ₹1.2 lakh+ on fees alone. Larger backlogs save several times that.
- ✅ Immunity under Section 92 and 137 is automatic if the form is filed before an adjudication notice or within 30 days of such notice.
- ✅ MSC-1 (dormant status) available at 50% normal fee. STK-2 (voluntary strike-off) available at 25% normal fee.
- ✅ DPT-3, DIR-3 KYC, MSME Form 1, BEN-2, INC-22A and INC-20A are NOT covered. File them under the normal regime.
- ✅ Section 164(2) director disqualification clock can be stopped by clearing the backlog before the three-year trigger or before ROC action.
- ✅ Start the process by 15 June 2026 at the latest. Board meeting backfill and AGM adoption take 4-6 weeks.
Sources and References
- MCA General Circular No. 01/2026 dated 24 February 2026 – Companies Compliance Facilitation Scheme, 2026 (primary authority)
- Companies Act, 2013 – Sections 92, 137, 164, 248, 403, 454, 460 (India Code)
- Companies (Registration Offices and Fees) Rules, 2014 – Additional fee slabs
- Taxmann analysis – CCFS 2026 scheme scope and eligibility
- Taxmann – MCA Launches CCFS for Delayed Filings with 10% Additional Fees
- Business Upturn – CCFS 2026 One-Time Amnesty Announcement
- Comparable precedent schemes: Companies Fresh Start Scheme (CFSS) 2020, Condonation of Delay Scheme (CODS) 2018, LLP Settlement Scheme 2020
Need Help Clearing Your ROC Backlog Before 15 July?
Use the MCA Penalty Calculator to estimate your current exposure and your CCFS 2026 savings.
For a confidential compliance audit and end-to-end CCFS filing support:
Contact CS Sapna Malpani | WhatsApp +91 96208 03375
Practising Company Secretary | Bangalore | 15+ years serving private companies and startups
Frequently Asked Questions
What is CCFS 2026 and who is eligible?
CCFS 2026 is the Companies Compliance Facilitation Scheme, 2026 notified by MCA vide General Circular No. 01/2026 dated 24 February 2026. It runs from 15 April 2026 to 15 July 2026 and allows defaulting companies to clear long-pending statutory filings by paying only 10% of the additional fees otherwise applicable. Every active company with overdue filings is eligible, except those facing strike-off action under Section 248, companies that have filed their own strike-off applications, dormant applicants prior to the scheme, entities dissolved through amalgamation, and vanishing companies.
Which forms can be filed under CCFS 2026?
Eleven categories of forms are covered. Annual return forms: MGT-7 and MGT-7A. Financial statement forms: AOC-4, AOC-4 CFS, and AOC-4 NBFC (Ind AS). Auditor appointment: ADT-1. Foreign company filings: FC-3 and FC-4. Legacy Companies Act 1956 forms: 20B, 21A, 23AC, 23ACA, 66, and 23B. Companies can also opt for Form MSC-1 (dormant status) at 50% of normal fees or Form STK-2 (voluntary strike-off) at 25% of normal fees.
How much can a private company actually save with CCFS 2026?
The savings scale with the delay. A private company with two years of missed annual filings (FY 2023-24 and FY 2024-25) would typically pay around ₹1,33,600 in additional fees. Under CCFS 2026, the same filings cost only ₹13,360 – a saving of ₹1,20,240. For longer defaults, savings can easily exceed ₹3 lakh. This is separate from the adjudication penalty under Section 454, which can independently reach ₹5 lakh for the company and ₹50,000 for each officer in default for breach of Section 92 or 137.
Does CCFS 2026 protect directors from disqualification under Section 164(2)?
The scheme does not explicitly restore directorships already cancelled under Section 164(2) for non-filing of annual returns or financial statements for three consecutive years. However, by clearing the backlog before Section 164(2) is triggered or before the ROC takes action, directors prevent disqualification entirely. Companies whose directors are already disqualified should consult a practising company secretary, because the relief under CCFS needs to be combined with an INC-28 or a writ remedy depending on the circumstances.
What happens if a company misses the 15 July 2026 deadline?
After 15 July 2026, the normal regime resumes. Additional filing fees revert to the standard slab (up to 12 times the base fee depending on delay). More importantly, Registrars of Companies may initiate adjudication proceedings under Section 454 for breach of Section 92 (annual return), Section 137 (financial statement filing) and related provisions. Penalty exposure jumps back to ₹10,000 minimum plus ₹100 per day of continuing default for Section 92, and ₹10,000 plus ₹100 per day for Section 137. Directors also face Section 164(2) disqualification risk.
Does CCFS 2026 cover DIR-3 KYC, DPT-3, MSME-1 or INC-22A?
No. CCFS 2026 is limited to the specific forms listed in the circular – primarily annual returns (MGT-7 family), financial statements (AOC-4 family), auditor appointment (ADT-1), foreign company filings (FC-3 and FC-4) and six legacy 1956 Act forms. DIR-3 KYC, DPT-3 (return of deposits), MSME Form 1, INC-22A (ACTIVE), BEN-2, INC-20A and other compliance forms are not covered. These continue to attract normal additional fees and adjudication penalties.
Can a company use CCFS 2026 if an adjudication notice has already been issued?
Conditional yes. If the notice was issued within the last 30 days and no adjudication order has been passed, the company can still file under CCFS 2026 and secure immunity from penalty for the Section 92 or 137 default. However, if more than 30 days have passed since the notice or if an adjudication order has already been passed, the penalty liability under that order survives – only the filing fee relief remains available.
Disclaimer: This article is for information only and does not constitute legal or professional advice. Fees and penalties are illustrative and may vary based on the company’s authorised capital slab, extent of delay, and specific facts. For a binding opinion on your case, engage a practising company secretary.