Starting April 15, 2026, companies with pending MCA filings can save up to 90% on late fees — but this window closes on July 15, 2026, and the MCA has warned that ROC action begins immediately after.
If your company has overdue annual returns, financial statements, or auditor appointment forms gathering dust on MCA-21, this is the compliance lifeline you have been waiting for. The Ministry of Corporate Affairs has launched the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) through General Circular No. 01/2026 dated 24th February 2026 — and it opens in just 3 days.
Here is everything you need to know to act before it is too late.
What Is CCFS-2026?
CCFS-2026 is a one-time compliance amnesty scheme by the MCA, active from 15th April 2026 to 15th July 2026. It allows companies to regularise their pending statutory filings with the Registrar of Companies (ROC) at massively reduced costs.
Think of it as the government saying: “We know you have been defaulting. File now at 10% of the penalty, or face the full force of the law after July 15.”
The last time something like this happened was the Companies Fresh Start Scheme (CFSS) in 2020. If you missed that window, you know how painful the accumulated penalties have been since.
The Problem: Accumulated Penalties Are Crippling Companies
Under normal circumstances, late filing of annual returns and financial statements attracts additional fees of ₹100 per day — with no upper cap. A company that missed filings for 3 years is looking at additional fees exceeding ₹1,00,000 per form. Multiply that across MGT-7, AOC-4, and ADT-1, and the total penalty burden can cross ₹5,00,000 or more.
Beyond the fees, the consequences compound rapidly. Directors of companies that have not filed annual returns for 3 consecutive financial years face disqualification under Section 164(2)(a) of the Companies Act, 2013. The ROC can initiate suo motu strike-off proceedings under Section 248. And once a company is struck off, reviving it through NCLT is a process that can take 12-18 months and cost lakhs in legal fees.
For a private limited company doing ₹10-50 crore in revenue, these are not abstract risks — they are existential ones. One disqualified director means frozen bank accounts, disrupted operations, and investor confidence in freefall.
What Changed: The Three Options Under CCFS-2026
The scheme provides three distinct pathways depending on your company’s situation:
Option 1: File Pending Annual Returns and Financial Statements (Save 90% on Late Fees)
If your company has overdue annual returns (MGT-7/MGT-7A) or financial statements (AOC-4/AOC-4 CFS/AOC-4 XBRL), you can file them during the scheme window by paying only 10% of the total accumulated additional fees. The normal filing fee still applies, but the late penalty — which is where the real pain lies — drops by 90%.
Example: If your company has accumulated ₹3,00,000 in additional fees for 3 years of missed AOC-4 filings, you pay just ₹30,000 under the scheme instead of ₹3,00,000.
Option 2: Apply for Dormant Status (50% Fee Reduction)
If your company is inactive but you do not want it struck off, you can apply for dormant status under Section 455 by filing Form MSC-1 at 50% of the standard filing fee. This keeps your company registered with minimal ongoing compliance requirements.
Option 3: Voluntary Strike-Off (75% Fee Reduction)
If you want to shut down your company cleanly, you can file Form STK-2 during the scheme period at just 25% of the applicable filing fee — effectively ₹2,500 instead of the normal ₹10,000. This is the cheapest and cleanest exit available.
Which Forms Are Covered?
The scheme covers a comprehensive list of annual filing forms:
- MGT-7 and MGT-7A — Annual Returns
- AOC-4, AOC-4 CFS, AOC-4 XBRL — Financial Statements
- AOC-4 NBFC (Ind AS) and AOC-4 CFS NBFC (Ind AS) — NBFC Financial Statements
- ADT-1 — Auditor Appointment
- FC-3 and FC-4 — Foreign Company Returns
- Form 20B, 21A, 23AC, 23ACA, 23AC-XBRL, 23ACA-XBRL — Legacy Forms under Companies Act, 1956
- Form 66 — Compliance Certificate
- Form 23B — Auditor Information
- MSC-1 — Dormant Status Application
- STK-2 — Strike-Off Application
Important exclusions: Forms INC-20A (Declaration of Commencement of Business) and DPT-3 (Return of Deposits) are NOT covered under this scheme. Also, you cannot use the scheme to correct past disclosures such as related party transaction details or AGM dates.
Who Cannot Avail This Scheme?
The scheme does not apply to companies that have been issued final strike-off notices under Section 248 of the Companies Act, 2013 (or Section 560 of the old Companies Act, 1956), companies that have already applied for voluntary strike-off before April 15, 2026, companies that filed dormant status applications before the scheme opened, and entities classified as “Vanishing Companies.”
What You Must Do Now: 7-Step Action Plan
Step 1: Audit your MCA filing status. Log in to MCA-21 V3 portal and check your company’s filing history. Identify every overdue form — annual returns, financial statements, and auditor appointments.
Step 2: Calculate your current penalty exposure. For each overdue form, calculate the additional fees at ₹100 per day from the due date to today. This is the number you are about to reduce by 90%.
Step 3: Get your documents in order. Ensure your financial statements are audited, board resolutions are passed, and the Annual General Meeting (if not held) is convened before filing. Remember — the scheme covers the penalty, not the underlying compliance.
Step 4: Engage your Company Secretary. A practising Company Secretary can certify your annual returns (MGT-7) and ensure all filings are accurate. Errors in scheme filings can lead to rejection and you lose the benefit.
Step 5: File on MCA-21 V3 starting April 15. The scheme window opens on April 15, 2026. The reduced fees apply automatically when you file the relevant e-forms during the scheme period.
Step 6: Secure your immunity. Under Sections 92 and 137 of the Companies Act, filings made before the adjudicating officer issues a notice — or within 30 days of such notice — receive immunity from penalty proceedings. File early to maximise this protection.
Step 7: Decide on dormant or strike-off if applicable. If your company is inactive, choose between dormant status (MSC-1 at 50% fee) or clean closure (STK-2 at 25% fee) based on whether you plan to reactivate in the future.
The Deeper Implication: What Happens After July 15?
The General Circular No. 01/2026 does not mince words. After the scheme closes on July 15, 2026, the ROC will initiate mandatory enforcement action against every company that remains in default. This includes adjudication notices for penalties under Section 454, suo motu strike-off proceedings under Section 248, and potential disqualification of directors under Section 164(2)(a).
The MCA is essentially drawing a line in the sand. This scheme is both a carrot and a warning: comply now at a fraction of the cost, or face the full weight of regulatory action later.
For founders and directors of companies in the ₹5 crore to ₹500 crore revenue range, director disqualification is not just a compliance issue — it freezes your ability to operate any company in India. Your DIN is deactivated, your bank signatories become invalid, and your other directorships are jeopardised. The downstream business impact can be catastrophic.
Key Takeaways
1. CCFS-2026 is a 3-month amnesty window from April 15 to July 15, 2026 — the first since CFSS-2020.
2. You can save 90% on accumulated late fees for annual filings, 50% on dormant status applications, and 75% on strike-off fees.
3. The scheme covers MGT-7, AOC-4, ADT-1, and several other forms — but NOT INC-20A or DPT-3.
4. Companies already under final strike-off notice or classified as “Vanishing Companies” are excluded.
5. Post-scheme, ROC enforcement is guaranteed — including director disqualification under Section 164(2)(a) and suo motu strike-off under Section 248.
6. Start preparing NOW. Get your financials audited, convene your AGM, and engage a practising Company Secretary before April 15.
Sources
MCA General Circular No. 01/2026 dated 24th February 2026 — Official MCA Circular
Companies Act, 2013 — Sections 92, 137, 164(2)(a), 248, 454, 455
ICSI Advisory on CCFS-2026 — ICSI Official Website
Frequently Asked Questions
Q1: Can I file forms for multiple years under CCFS-2026?
Yes. The scheme allows you to file overdue forms for all pending financial years. You will need to file them sequentially — starting with the earliest year and working forward — and pay 10% of accumulated additional fees for each form.
Q2: My company has not held an AGM for 2+ years. Does the scheme cover that?
No. The scheme addresses the filing of annual returns and financial statements, not the non-conduct of AGMs. You will need to regularise AGM compliance separately, potentially by applying to the Registrar for an extension under Section 96(1) or approaching the NCLT.
Q3: Will I still face prosecution for past defaults after filing under the scheme?
Under the immunity provisions, if you file before the adjudicating officer has issued a notice — or within 30 days of receiving such notice — you will not face penalty proceedings for the relevant sections. However, penalties already imposed through adjudication orders before the scheme period remain payable.
Q4: My directors are already disqualified under Section 164(2). Can this scheme help?
The scheme helps you file the overdue documents that caused the disqualification. Once all pending annual returns and financial statements are filed and the company becomes compliant, the disqualification can potentially be addressed. However, the scheme itself does not automatically reverse an existing disqualification — you may need to approach the NCLT for that.
Q5: What is the cost of NOT using this scheme?
After July 15, 2026, you pay 100% of accumulated additional fees (₹100/day, uncapped), face potential adjudication penalties under Section 454, risk director disqualification under Section 164(2)(a), and your company could be struck off under Section 248. For a company with 3 years of pending filings, the total exposure can easily exceed ₹5-10 lakhs — compared to under ₹1 lakh if you file during the scheme.
Do Not Wait Until July
The scheme opens on April 15, 2026, and closes on July 15, 2026. But the smart move is to file in the first 2-3 weeks while the MCA portal is not overloaded with last-minute filings. Every scheme window sees a surge of filings in the final week, leading to portal crashes and missed deadlines.
Need help assessing your company’s filing status and calculating your penalty savings? Book a consultation with CS Sapna Malpani — Practising Company Secretary in Bangalore — and get your compliance sorted before the window opens.
Use our MCA Compliance Checklist Tool to quickly identify your overdue filings and estimate your savings under CCFS-2026.