By Shahi & Co., Chartered Accountants · New Delhi · 12 March 2026
The Ministry of Corporate Affairs has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) vide General Circular No. 01/2026 dated 24 February 2026. The scheme allows defaulting companies to regularise pending Annual Returns and Financial Statements by paying just 10% of accumulated additional fees — instead of the standard ₹100 per day with no upper limit. The window is open from 15 April 2026 to 15 July 2026. For any company that has missed ROC filings, this is the most significant compliance opportunity in years.
CCFS stands for Companies Compliance Facilitation Scheme. It is a one-time amnesty initiative under the Companies Act, 2013. The scheme does not waive the normal prescribed filing fee — the base fee for each form remains fully payable. However, the accumulated additional fee of ₹100 per day (charged without any ceiling since 1 July 2018) is reduced to just 10% of whatever has accumulated.
For a company that has not filed MGT-7 for three consecutive years, the additional fee liability alone can exceed ₹1 lakh per form. Under CCFS 2026, that company pays only ₹10,000 in additional fees per form — a saving of over 90%.
General Circular No. 01/2026 dated 24 February 2026, Ministry of Corporate Affairs. Operative under the Companies Act, 2013 and the Companies (Registration Offices and Fees) Rules, 2014.
With over 20 lakh active companies on the MCA registry, a significant backlog of unfiled annual compliance documents has accumulated — particularly among MSMEs, One Person Companies, startups, and dormant companies. Key drivers behind the scheme:
15 April 2026 to 15 July 2026. The 10% additional fee concession applies automatically on the MCA V3 portal during this window — no separate application form is required.
| Filing Component | Normal Position | Under CCFS 2026 |
|---|---|---|
| Normal filing fee (MGT-7 / AOC-4) | ₹300–₹600 based on share capital | Fully payable — no waiver |
| Additional fee (delay penalty) | ₹100/day, no upper limit | Only 10% of accumulated total |
| Dormant status — MSC-1 | Normal fee as per Rules | 50% of normal fee |
| Voluntary strike-off — STK-2 | ₹10,000 | 25% of normal fee |
A private limited company has not filed MGT-7 and AOC-4 for four financial years (FY 2021-22 to FY 2024-25). At ₹100/day, accumulated additional fees per form could exceed ₹1.4 lakhs. Under CCFS 2026, only ₹14,000 per form is payable as additional fee — a combined saving of over ₹2.5 lakhs across both forms, plus immunity from prosecution.
For companies that are operationally active but have accumulated years of missed Annual Returns and Financial Statements. File all overdue MGT-7, MGT-7A, and AOC-4 forms during the scheme window, paying the normal base fee plus only 10% of the accumulated additional fee. This is the primary avenue for the majority of defaulting companies.
For inactive companies that wish to remain on the register with minimal ongoing obligations. Section 455 of the Companies Act permits dormant status by filing e-Form MSC-1, which attracts only 50% of normal fees under CCFS 2026. A dormant company is subsequently required to file only Form MSC-3 annually — a substantially lighter compliance burden.
For companies that have permanently ceased operations. Voluntary strike-off under Section 248 by filing e-Form STK-2 attracts only 25% of the normal filing fee during the scheme window — the most cost-effective opportunity to formally close a dormant company and eliminate future compliance obligations.
| Form | Purpose | Applicable To |
|---|---|---|
| MGT-7 | Annual Return | All companies except OPC / Small Companies |
| MGT-7A | Simplified Annual Return | One Person Companies & Small Companies |
| AOC-4 | Financial Statements | All companies |
| AOC-4 CFS | Consolidated Financial Statements | Companies with subsidiaries |
| AOC-4 NBFC (Ind AS) | NBFC Financial Statements | NBFCs under Ind AS |
| AOC-4 XBRL | Financial Statements in XBRL | Listed & specified companies |
| ADT-1 | Auditor Appointment | All companies |
| FC-3 / FC-4 | Annual Accounts & Annual Return | Foreign companies registered in India |
| Form 20B / 21A | Annual Return (1956 Act) | Legacy companies |
| Form 23AC / 23ACA | Balance Sheet (1956 Act) | Legacy companies |
| Form 66 / 23B | Compliance & Auditor Info (1956 Act) | Legacy companies |
CCFS 2026 covers annual return and financial statement filings only. Event-based forms such as DIR-12, SH-7, PAS-3, or charge-related forms are not covered under this scheme.
Any company registered under the Companies Act, 2013 or 1956 that has defaulted in filing any covered form is eligible — including private limited companies, public limited companies, OPCs, small companies, Section 8 companies, producer companies, MSMEs, startups, and foreign companies registered in India.
Immunity from prosecution under Sections 92 (Annual Return) and 137 (Financial Statements) of the Companies Act, 2013 is arguably the most significant benefit of CCFS 2026. However, it is conditional on the timing of filing:
| Situation at Time of Filing | Immunity Available? |
|---|---|
| Filing made before any adjudication notice is issued | ✅ Full immunity — proceedings concluded |
| Filing made within 30 days of adjudication notice | ✅ Immunity — proceedings to be concluded |
| Filing made after 30 days from adjudication notice | ❌ No immunity — penalty liability remains |
| Final adjudication order already passed | ❌ No immunity — order remains enforceable |
Immunity under CCFS 2026 is strictly limited to delayed-filing penalties under Sections 92 and 137. It does not cover other violations — board meeting defaults, statutory register failures, FEMA, SEBI, or other regulatory statutes. Director disqualification under Section 164(2) is a separate matter requiring independent legal advice.
Log into the MCA V3 portal (mca.gov.in) and check your company's Master Data. Identify all pending MGT-7 / MGT-7A and AOC-4 filings, along with the exact financial years for which returns are outstanding.
For companies that have been inactive over multiple years, financial statements may need reconstruction from available records. Board approval is mandatory before filing financial statements. Ensure signed Balance Sheets, Profit & Loss accounts, and Auditor's Reports are ready for each pending financial year.
ADT-1 is a covered form under CCFS 2026. If auditor appointment filings are also pending, they should be filed during the scheme window. A missing or incorrect auditor record on MCA can complicate financial statement filings.
If any director's DIN has been disqualified under Section 164(2) due to non-filing, the company cannot process filings through that DIN. DIN reactivation must be addressed before proceeding — seek professional guidance specific to the director's situation.
File MGT-7 / MGT-7A and AOC-4 through the MCA V3 portal between 15 April and 15 July 2026. The portal automatically calculates and applies the 10% additional fee during the scheme window. No separate application or additional form is required.
After each successful filing, download and retain the SRN (Service Request Number) acknowledgement. Immunity attaches to the actual filing date — documentary evidence of timely filing within the scheme window is essential.
Do not wait until July. MCA portals experience severe congestion as deadlines approach. A filing attempted on 14 July 2026 that fails due to server errors will not receive the scheme benefit. Starting in April or early May is strongly advisable.
The MCA circular is explicit: upon conclusion of CCFS 2026, Registrars of Companies will initiate action against all companies that remain in default. Based on prior MCA enforcement patterns, this is likely to include:
There is no indication that MCA will announce another facilitation scheme in the near future. Companies that do not avail CCFS 2026 will face the full burden of accumulated penalties plus enforcement proceedings.
No. CCFS 2026 applies only to companies under the Companies Act, 2013 and 1956. LLPs are governed separately under the Limited Liability Partnership Act, 2008 and the MCA LLP Rules. No parallel scheme for LLPs has been announced as of March 2026.
No separate application form is required. Unlike the earlier CFSS 2020 (which required Form CFSS-2020), CCFS 2026 operates through the standard annual return and financial statement forms on the MCA V3 portal, with the 10% additional fee applied automatically.
No. Companies against which the Registrar has already issued the final Section 248 strike-off notice are expressly excluded. If a show cause notice (not final notice) has been issued, the company may still be eligible — the distinction is important and professional advice is recommended.
Not automatically. Filing the overdue returns removes the ongoing default going forward. Whether a pre-existing Section 164(2) disqualification is simultaneously remedied depends on specific facts, pending litigation, and prevailing judicial interpretation. Independent legal advice is essential for directors with disqualified DINs.
Yes. The scheme covers filings regardless of whether the company was operationally active or completely dormant in the relevant financial year. Filing NIL returns for inactive years is one of the principal scenarios this scheme is designed to address.
If a final adjudication order has been passed and no appeal is pending, immunity under CCFS 2026 does not override that order — the penalty remains payable. If the order was passed recently, an appeal to the Regional Director under Section 454(5) may be considered with appropriate professional guidance.
Yes, provided the company files within 30 days of the adjudication notice. A mere show cause notice does not disqualify the company — it is only a final adjudication order that eliminates the immunity benefit.
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