Key Takeaways
- MCA General Circular No. 01/2026 launched the Companies Compliance Facilitation Scheme 2026.
- Window: April 15 to July 15, 2026. No extensions expected.
- 90% waiver on additional late fees for pending ROC filings (MGT-7, AOC-4, ADT-1, and more).
- Dormant status at 50% fees, voluntary strike-off at 25% fees also available.
The Ministry of Corporate Affairs issued General Circular No. 01/2026 on February 24, 2026, announcing the Companies Compliance Facilitation Scheme 2026. This is a one-time amnesty for companies with overdue filings, and the window is limited.
If your company has pending annual returns or financial statements from past years, this scheme lets you clear the backlog at a fraction of the normal penalty cost.
Looking for expert help with CCFS-2026 amnesty scheme company filing assistance? The team at TaxGarden helps Indian SMEs stay compliant end-to-end — filings, notices, and advisory, all in one place.
Eligible Forms Under CCFS-2026
The scheme covers a wide range of overdue ROC filings:
| Form | Purpose | Typical Late Fee (Per Year) |
|---|---|---|
| MGT-7 | Annual Return (companies with share capital) | Rs 12,000+ |
| MGT-7A | Annual Return (small/one-person companies) | Rs 6,000+ |
| AOC-4 | Financial Statements | Rs 12,000+ |
| AOC-4 CFS | Consolidated Financial Statements | Rs 12,000+ |
| ADT-1 | Auditor Appointment | Rs 3,600+ |
| FC-3 | Annual Return of Foreign Company | Varies |
| FC-4 | Financial Statements of Foreign Company | Varies |
| Legacy 1956 Act forms | Pending from Companies Act 1956 era | Varies |
The actual additional fee depends on the delay period and company type. For a small company that has not filed for 3 years, the accumulated additional fees across all forms can easily reach Rs 1,00,000 or more.
Fee Calculation Under the Scheme
Under CCFS-2026, you pay:
- 100% of the normal filing fee (no waiver on this)
- Only 10% of the additional (late) fee (90% waiver)
Detailed Example
A Private Limited Company (authorized capital Rs 10 lakh) has not filed for FY 2022-23, FY 2023-24, and FY 2024-25. Pending forms: AOC-4 and MGT-7 for each year (6 filings total).
Without scheme:
- Normal fee per form: Rs 300
- Additional fee per form (approx): Rs 12,000 per year
- Total for 6 filings: Rs 1,800 (normal) + Rs 72,000 (additional) = Rs 73,800
With CCFS-2026:
- Normal fee per form: Rs 300
- Additional fee per form (10% of Rs 12,000): Rs 1,200 per year
- Total for 6 filings: Rs 1,800 (normal) + Rs 7,200 (additional) = Rs 9,000
Savings: Rs 64,800 (88% total savings)
Prosecution Immunity
One of the most valuable benefits of CCFS-2026 is prosecution immunity:
- If you file all overdue returns under the scheme before any adjudication notice is issued, you are immune from prosecution for those specific filing defaults.
- This protects directors from potential imprisonment and fines under Section 92(5) and Section 137(3) of the Companies Act 2013.
- The immunity applies only to filing defaults covered by the scheme, not to other violations like fraud or misrepresentation.
Important Condition
If an adjudication order has already been passed for your non-filing, the scheme does not reverse that order. File before any adjudication to get immunity.
Option 1: Dormant Status (Form STK-1)
If your company is not actively operating, you can apply for dormant status under CCFS-2026 at 50% of the regular filing fee.
Requirements:
- No significant accounting transactions for the past 2 financial years
- No pending litigation against the company
- Board resolution approving the application
- All statutory dues (tax, GST, PF, ESI) must be cleared or current
Benefits of dormant status:
- Reduced annual filing requirements
- Lower compliance costs
- Company remains registered and can be reactivated
- CIN and name are preserved
- Director DIN status remains active
Reactivation process:
- File Form MSC-4 (Application for Active Status)
- Pay applicable fees
- Resume full filing compliance
Option 2: Voluntary Strike-Off (Form STK-2)
If you want to permanently close the company, CCFS-2026 offers voluntary strike-off at 25% of the regular fee.
Requirements:
- No operations for the past 2 years, or company never commenced business
- No pending liabilities (creditors, tax dues, legal claims)
- All assets distributed or sold
- Board and shareholders must pass special resolution
- No pending proceedings against the company
Process:
- Clear all pending filings under CCFS-2026 first
- File Form STK-2 with ROC
- Pay 25% of the normal fee
- ROC publishes notice for stakeholder objections (30 days)
- If no objections, company is struck off the register
Warning: Strike-off is permanent. The company name, CIN, and all associated registrations are terminated. Directors remain liable for any undisclosed liabilities discovered after strike-off.
Looking for expert help with company dormant status and voluntary strike-off services India? The team at TaxGarden helps Indian SMEs stay compliant end-to-end — filings, notices, and advisory, all in one place.
Step-by-Step Filing Process
Phase 1: Assessment (April 15 to April 30)
- Check compliance status on the MCA V3 portal
- List all pending forms with their due dates
- Calculate fee payable under the scheme
- Assess whether you want to continue, go dormant, or strike off
Phase 2: Document Preparation (May 1 to June 15)
- Prepare audited financial statements for each pending year (required for AOC-4)
- If books are not maintained, reconstruct accounts from bank statements and available records
- Get the auditor to sign off on each year's financials
- Compile annual return data for MGT-7 (shareholder register, share transfer details, board meetings)
- Pass board resolutions authorizing the filing of overdue returns under CCFS-2026
Phase 3: Filing (June 15 to July 10)
- File forms on the MCA portal in chronological order, starting from the oldest year
- Pay reduced fees at the time of filing
- Note the SRN (Service Request Number) for each filing
- Monitor processing status on the portal
Phase 4: Verification (By July 15)
- Confirm all filings are processed and accepted
- Verify compliance status shows as "compliant" on MCA portal
- Download receipts and acknowledgements for your records
Director Disqualification Risk
This is the most serious consequence of continued non-filing. Under Section 164(2) of the Companies Act 2013:
- If a company fails to file annual returns or financial statements for 3 continuous years, its directors are disqualified.
- Disqualified directors cannot be appointed as directors in any company for 5 years.
- Disqualification affects all directorships, not just the defaulting company.
- Existing directorships in other companies may also be impacted.
CCFS-2026 is an opportunity to clear the filing backlog and prevent or reverse the disqualification process.
After July 15: What Happens
MCA has explicitly warned of enforcement action against companies that remain non-compliant after the scheme window closes:
- Full additional fees (no waiver) on any future filings
- Prosecution proceedings against directors
- Director disqualification enforcement
- ROC-initiated strike-off (involuntary, without your consent)
- Freezing of company bank accounts in extreme cases
Let TaxGarden Handle Your CCFS-2026 Filings
Preparing multi-year financial statements, compiling annual returns, and filing each form correctly on the MCA portal is time-intensive work. TaxGarden's company compliance team manages the entire process from document preparation to MCA filing under CCFS-2026.
Frequently Asked Questions
Can I file only some overdue forms under CCFS-2026?
Yes. You can file individual forms. However, to achieve full compliance and director disqualification protection, it is recommended to file all pending forms.
Does CCFS-2026 apply to LLPs?
No. CCFS-2026 applies only to companies registered under the Companies Act 2013 (or its predecessor, Companies Act 1956). LLPs have separate compliance requirements under the LLP Act.
What if I cannot prepare financial statements in time?
Start immediately. If full audited accounts cannot be prepared before July 15, prioritize the earliest years first. Partial compliance is better than no compliance.
Is there any penalty for using the scheme?
No penalty for using the scheme. You pay the normal filing fee plus only 10% of the additional fee. The scheme itself is an incentive, not a penalty.
Can Section 8 (non-profit) companies use CCFS-2026?
Yes. Section 8 companies with overdue ROC filings are eligible for the scheme and can file at the reduced fee rates.
