Companies Compliance Facilitation Scheme, 2026: A One-Time Window to Clear MCA Defaults at a Fraction of the Cost

The Ministry of Corporate Affairs has opened a three-month amnesty window running from 15 April to 15 July 2026, for companies to regularise years of pending annual filings, apply for dormancy, or close permanently, at significantly reduced fees. For MSMEs and private companies that have accumulated daily late fees running into lakhs under Section 403 of the Companies Act, this is a one-time opportunity that will not repeat. This brief covers everything you need to know: what the scheme offers, who can use it, how immunity from penalties works, and exactly what to do before 15 July 2026.

OFFICIAL REFERENCE

What is CCFS-2026 and Why Has It Been Introduced?

CCFS-2026 is a one-time amnesty scheme notified by the Ministry of Corporate Affairs vide General Circular No. 01/2026 [F.No. Policy-02/2/2020-CL-V] dated 24 February 2026, exercised under Section 460 read with Section 403 of the Companies Act, 2013. The scheme is open from 15 April 2026 to 15 July 2026, a strictly time-bound window of exactly three months. The legal authority for the fee relief flows from Section 460, which empowers the Central Government to condone delays in filings, and Section 403, which governs additional fees payable for late filing.

The background to this scheme is the substantial accumulation of compliance defaults across Indian companies, particularly MSMEs and private limited companies. Under the current fee structure, the additional fee for delayed filing under Section 403 runs at ₹100 per day with no upper cap. A company that has not filed its Annual Return (Form MGT-7) for even two years faces an additional fee of approximately ₹73,000. For each additional year of delay, the burden grows by a further ₹36,500. For companies that have been non-compliant for several years, the total additional fees can easily cross ₹2–5 lakh per form, making voluntary regularisation financially unviable without a scheme like this. CCFS-2026 is the government's recognition of this structural problem and a practical resolution route.

THREE OPTIONS UNDER THE SCHEME

File, Go Dormant or Close: Choose the Route That Fits Your Company

Option 1: Clear Pending Annual Filings. Companies that are operational but have accumulated filing delays can file their pending Annual Returns and Financial Statements by paying the normal filing fee plus only 10% of the additional fees otherwise payable. This is the core of the scheme and the option most companies will use. The 90% waiver on additional fees is the headline benefit. Example: a company with ₹50,000 in accumulated additional fees pays only ₹5,000 under the scheme, saving ₹45,000 on that one form alone.

Option 2: Apply for Dormant Status (Section 455, e-Form MSC-1). Inactive companies that are not currently operating but want to preserve their corporate entity for a future revival can apply for Dormant Status by filing e-Form MSC-1, paying only 50% of the normal dormancy filing fee. Dormant companies have minimal annual compliance requirements going forward. In practice this means just an annual return confirming their dormant status. This is the appropriate route for startups between funding rounds, family companies between generations, or businesses temporarily wound down due to market conditions. Option 3: Apply for Strike-Off (Section 248, e-Form STK-2). Companies that are completely defunct and no longer needed can apply for voluntary closure by filing e-Form STK-2, paying only 25% of the normal strike-off filing fee. Once struck off, the company ceases to exist as a legal entity with no further compliance obligations. This route is permanent and irreversible. It should only be chosen where the company has settled all liabilities, has no ongoing business, and promoters have confirmed there is no intent to revive it.

OPTION	FORM	FEE UNDER CCFS-2026	WHO SHOULD USE
File Pending Returns	MGT-7 / AOC-4 etc.	Normal fee + 10% of additional fees	Operational companies with filing backlog
Go Dormant	MSC-1	50% of normal dormancy fee	Inactive companies, may revive in future
Strike Off	STK-2	25% of normal strike-off fee	Defunct companies with no revival intent

FORMS COVERED

Every Form That Can Be Filed Under the Scheme, Including Legacy 1956 Act Forms

The scheme covers a comprehensive list of compliance forms under both the Companies Act, 2013 and the Companies Act, 1956. Under the Companies Act, 2013: MGT-7 (Annual Return for large companies), MGT-7A (Annual Return for small companies and OPCs), AOC-4 (Financial Statements), AOC-4 CFS (Consolidated Financial Statements), AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), AOC-4 XBRL, ADT-1 (Appointment of Auditor), FC-3 (Return of Overseas Investment), and FC-4 (Return on Foreign Remittance).

Under the Companies Act, 1956, covering legacy filings that remain pending from the old regime, the scheme covers: Form 20B (Annual Return), Form 21A (Board's Report), Form 23AC (Balance Sheet), Form 23ACA (Profit & Loss Statement), Form 23AC-XBRL, Form 23ACA-XBRL, Form 66 (Return of Allotment), and Form 23B (Consolidated Financial Statements). This backward coverage is significant. Many older companies incorporated before 2013 have pending filings from the old Companies Act regime that have been sitting unaddressed. All of these can now be regularised under CCFS-2026 at the same 10% additional fee rate. This means most pending annual compliance defaults from any year can be addressed through this single scheme.

EXCLUSIONS — WHO CANNOT USE THIS SCHEME

Five Categories of Companies That Are Not Eligible

The scheme is not available to all defaulting companies. Five categories are explicitly excluded. First, companies against which the Registrar of Companies has already issued a final notice for striking off under Section 248 of the Companies Act, 2013 (or the earlier Section 560 of the 1956 Act). These companies are already in active enforcement proceedings and cannot use the scheme to halt or reverse that process. Second, companies that have already applied for strike-off: if STK-2 was filed before 15 April 2026, the scheme does not apply. Third, companies that have already obtained Dormant Status under Section 455 before the scheme opens. The dormancy fee concession under CCFS-2026 applies only to new applications made within the window.

Fourth, companies that have been dissolved pursuant to a scheme of amalgamation. These companies have already ceased to exist as separate entities. Fifth, companies classified as vanishing companies, a category of companies that cannot be traced at their registered address, have not filed returns for several years, and whose promoters cannot be located. These are subject to special enforcement mechanisms and are excluded from this general amnesty. If your company does not fall into any of these five categories and has pending filings, it is almost certainly eligible. When in doubt, verify your company's status on the MCA21 portal before proceeding.

IMMUNITY FROM PENALTIES — THE CRITICAL NUANCE

Immunity Is Not Automatic: Timing and Prior Notices Determine Your Protection

For defaults under Sections 92 and 137 (non-filing of Annual Returns and Financial Statements), immunity from penalties operates as follows. Full immunity is granted if: (a) the filings are completed before a notice is issued by an adjudicating officer, OR (b) the filings are completed within 30 days of the notice being issued. If either of these conditions is met, no penalty will be levied on the company or its officers in default. However, if 30 days have already expired after an adjudication notice was issued and no filing was made in that period, immunity from the already-imposed penalty is not available, but the 10% additional fee relief still applies. The fee relief and the immunity benefit operate independently; loss of one does not mean loss of the other.

For the other forms covered by the scheme (ADT-1, FC-3, FC-4, and the legacy 1956 Act forms), immunity from future penal action is available if all three of the following conditions are met: (1) the form is filed under CCFS-2026 during the window, (2) no prosecution has been filed against the company before the filing, and (3) no show cause notice for adjudication has been issued before the filing. If a show cause notice has already been issued before you file, you lose the immunity benefit for future penal action, though the reduced fee still applies. The practical implication: companies should verify their adjudication status on the MCA portal and file as early as possible within the window, before any notices are issued.

FEE STRUCTURE — THE NUMBERS

How Much You Actually Pay Under CCFS-2026

The additional fee under Section 403 accrues at ₹100 per day of delay from the due date of filing, with no upper cap. A company that has not filed MGT-7 for three years has accumulated additional fees of approximately ₹1,09,500 (1,095 days × ₹100/day) on that single form alone, before even counting the accumulation on AOC-4, AOC-4 CFS, and other forms. Under CCFS-2026, the company pays only 10% of this: ₹10,950 in additional fees, saving ₹98,550 on just one form. A company with filings pending across three years and two forms (MGT-7 and AOC-4) could save in excess of ₹1.5 lakh through this scheme.

WHAT HAPPENS AFTER 15 JULY 2026

ROC Enforcement Resumes in Full After 15 July 2026

The General Circular is explicit: after the scheme period ends on 15 July 2026, the Registrar of Companies will initiate action against companies that have not regularised their filings and have not opted for dormancy or strike-off under the scheme. The nature of post-scheme enforcement covers initiation of strike-off proceedings under Section 248 against non-compliant companies, imposition of penalties under Sections 92 and 137 for Annual Return and Financial Statement defaults, show cause notices for adjudication proceedings, prosecution in severe cases of long-standing default, and removal of company names from the register of companies.

It is important to note that CCFS-2026 comes after a series of earlier one-time schemes, including CFSS-2020, and the government has signalled that this is a final clean-up window before enforcement intensity increases. Companies that have used previous amnesty schemes without fully clearing their backlog and then re-accumulated defaults may receive particularly close scrutiny post-July. For directors personally, continued non-compliance after the scheme window increases personal exposure under Sections 92(5) and 137(3) of the Companies Act, which impose penalties directly on officers in default.

HOW TO FILE — STEP BY STEP

The Filing Process on MCA V3 Portal

Step 1: Check company status. Log in to the MCA21 portal (mca.gov.in) using director credentials. Go to the company dashboard and identify all pending/overdue filings. Verify that the company does not fall in any of the five excluded categories. Step 2: Choose your option. Decide between Option 1 (filing), Option 2 (dormancy via MSC-1), or Option 3 (strike-off via STK-2). If filing, identify every pending form (MGT-7, AOC-4, ADT-1, and others) across all financial years. Step 3: Prepare documents. For Option 1, prepare or obtain the signed Annual Return, audited financial statements, and board resolutions for each pending year. For Option 2 or 3, prepare the relevant supporting documents as required by the e-form instructions.

Step 4: File on MCA V3. The MCA V3 system will automatically calculate fees at the reduced CCFS-2026 rate when you select and file the form during the scheme window. Pay the reduced fees online through the portal. Upload all required supporting documents and submit. Step 5: Track and confirm. After submission, monitor the SRN (Service Request Number) on the MCA portal. Once accepted, the filing is complete and immunity benefits are effective from that date. For strike-off and dormancy applications, there is an additional ROC review step before final orders are passed. Engage a practising Company Secretary or Chartered Accountant for the filings, particularly for Options 2 and 3 where the irreversibility and procedural requirements are more complex.

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TRUSTFACTON — CCFS-2026

TRUSTFACTON

www.evensetconsultancy.com

This brief is for general information only and does not constitute legal, tax, or financial advice.
Please verify with primary sources and consult your CA, CS, or advisor before acting.