How the CCFS 2026 Amnesty Scheme Cuts ROC Late Fees

The Ministry of Corporate Affairs issued General Circular No. 01/2026 on February 24, 2026, announcing the Companies Compliance Facilitation Scheme 2026. It was a one-time amnesty for companies with overdue filings, open from 15 April 2026. After two extensions it closed on 15 September 2026.

The scheme is no longer available. This guide explains how it worked and what companies with forms still pending must do now, at standard fees.

Eligible Forms Under CCFS-2026

The scheme covered a wide range of overdue ROC filings:

For AOC-4 and MGT-7 the additional fee is Rs 100 per day of delay per form, with no upper cap, so one form a year late carries Rs 36,500. For a small company that has not filed for 3 years, the additional fees across all forms easily cross Rs 3,00,000, as the example below shows.

Fee Calculation Under the Scheme

Under CCFS-2026, companies paid:

• 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 (authorised capital Rs 10 lakh) had not filed AOC-4 and MGT-7 for FY 2022-23, FY 2023-24 and FY 2024-25 (6 filings). Assume the AGM for each year was due on 30 September, so AOC-4 fell due on 30 October and MGT-7 on 29 November, and all six forms were filed on 1 July 2026.

Without the scheme: Rs 2,400 normal fees (Rs 400 per form for this capital slab) + Rs 3,56,600 additional fees = Rs 3,59,000.

With CCFS-2026: Rs 2,400 normal fees + Rs 35,660 (10% of additional fees) = Rs 38,060.

The same six forms filed today pay the full additional fee, and it keeps growing by Rs 600 a day (Rs 100 for each of the six forms) until they are filed.

Saving under the scheme: Rs 3,20,940 (about 89% of the total).

Immunity From Penalty Proceedings

One of the most valuable benefits of CCFS-2026 was immunity:

• Companies that filed their overdue returns under the scheme got immunity from penalty proceedings for those specific filing defaults.
• This covered penalties on the company and its officers in default 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 imposing a penalty under Section 92 or Section 137 had already been passed, the scheme did not give immunity for that default.

Option 1: Dormant Status (Form MSC-1)

During the scheme, an inactive company could file its overdue forms and apply for dormant status under Section 455 in Form MSC-1 at 50% of the normal filing fee. After 15 September 2026 the full MSC-1 fee applies.

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)

During the scheme, a company that wanted to close could file its overdue forms and apply for voluntary strike-off in Form STK-2 at 25% of the normal fee. After 15 September 2026 the full STK-2 fee applies.

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:

1. Clear all pending filings first (now at full additional fees)
2. File Form STK-2 with ROC
3. Pay the STK-2 fee
4. ROC publishes notice for stakeholder objections (30 days)
5. 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.

Step-by-Step Filing Process

Deadline Timeline

CCFS-2026 Filing Timeline

Archived plan. The original July 15 cutoff was extended twice; the scheme finally closed on 15 September 2026.

1. Apr 15 : Apr 30

   Phase 1: Assessment

   Check compliance status on MCA V3 portal, list all pending forms, and decide whether to continue, go dormant, or strike off

2. May 1 : Jun 15

   Phase 2: Document Preparation

   Prepare audited financial statements for each pending year, get auditor sign-off, and compile annual return data for MGT-7

3. Jun 15 : Jul 10

   Phase 3: Filing

   File forms on MCA portal in chronological order (oldest year first), pay reduced fees, and note the SRN for each filing

4. Sep 15 [CLOSED]

   Phase 4: Verification : SCHEME CLOSED

   Extended from July 15 to August 31 (General Circular 03/2026), then to September 15, 2026 (General Circular 04/2026). Forms filed after that date attract the full additional fee.

Source: MCA General Circular No. 01/2026 : Companies Compliance Facilitation Scheme 2026

Phase 1: Assessment (April 15 to April 30)

1. Check compliance status on the MCA V3 portal
2. List all pending forms with their due dates
3. Calculate fee payable under the scheme
4. Assess whether you want to continue, go dormant, or strike off

Phase 2: Document Preparation (May 1 to June 15)

5. Prepare audited financial statements for each pending year (required for AOC-4)
6. If books are not maintained, reconstruct accounts from bank statements and available records
7. Get the auditor to sign off on each year's financials
8. Compile annual return data for MGT-7 (shareholder register, share transfer details, board meetings)
9. Pass board resolutions authorizing the filing of overdue returns under CCFS-2026

Phase 3: Filing (June 15 to July 10)

10. File forms on the MCA portal in chronological order, starting from the oldest year
11. Pay reduced fees at the time of filing
12. Note the SRN (Service Request Number) for each filing
13. Monitor processing status on the portal

Phase 4: Verification (Scheme Closed 15 September 2026)

Note: CCFS 2026 was originally due to end on July 15, 2026. MCA extended it to August 31 and then to September 15, 2026, and it closed on that date. Any form filed after September 15 attracts the full additional fee.

For companies with pending filings:

• Contact a compliance professional to assess current penalty exposure
• File overdue returns at standard fees to prevent further disqualification or enforcement
• Consider voluntary strike-off if the company is dormant

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 has closed, but filing the pending returns now still stops the 3-year default count from running further.

After 15 September 2026: Standard Fees and Penalties

The CCFS 2026 scheme closed on 15 September 2026. Companies that still have forms pending face:

• The full additional fee of Rs 100 per day of delay per form, with no waiver
• Penalty proceedings under Sections 92 and 137 of the Companies Act, 2013
• Director disqualification under Section 164(2) after 3 continuous years of default
• ROC-initiated strike-off under Section 248

Still Have Overdue ROC Filings? File Now Under Standard Penalties

The CCFS 2026 amnesty scheme has expired. Companies with pending filings now face full penalties. However, filing overdue returns immediately prevents further disqualification or enforcement action.

Tax Garden's ROC compliance team can prepare multi-year financial statements, compile annual returns, and file all overdue forms on the MCA portal at standard fees. Contact us for a compliance assessment.

Frequently Asked Questions

Is the CCFS-2026 scheme still open for filing overdue ROC forms?

No. The Companies Compliance Facilitation Scheme 2026 has closed. After two extensions, its final deadline was 15 September 2026. Overdue AOC-4, MGT-7 and other forms filed now attract the full additional fee of Rs 100 per day of delay, with no 90% waiver, so the sooner a pending form is filed, the smaller the fee and the lower the enforcement risk.

I filed some forms under CCFS-2026 but missed others. What happens now?

Forms filed and paid within the scheme window keep the reduced fee and the scheme's protection for those defaults. Any form not filed by 15 September 2026 is now outside the scheme and attracts full additional fees and possible penalty proceedings under Sections 92 and 137 of the Companies Act, 2013. File the remaining forms in chronological order, oldest year first, as soon as possible.

Can a disqualified director be reinstated after the company files its pending returns?

Filing the pending returns does not automatically remove a disqualification under Section 164(2) that has already been recorded. The disqualification runs for 5 years from the date of the default. Directors usually approach the National Company Law Tribunal or the High Court for relief, or MCA may remove it where the default is cured under a notified scheme, so check your DIN status on the MCA portal.

What are the options for a company that has no business and many overdue filings?

It can file the overdue forms and then apply for dormant status in Form MSC-1 under Section 455, which reduces annual compliance, or file the overdue forms and apply for voluntary strike off in Form STK-2 under Section 248. Strike off needs no liabilities, a special resolution or consent of 75% of members, and an indemnity bond from directors. Without the scheme, standard fees now apply.

How much is the late fee for a delayed AOC-4 or MGT-7 now?

Both forms attract an additional fee of Rs 100 per day of delay over the normal filing fee, with no upper cap, for each form and each year. A form delayed by one year therefore carries about Rs 36,500 in additional fees. Separate penalties can also be levied on the company and its officers in default through adjudication under the Companies Act.