CCFS-2026: How to Clear Your Pending ROC Filings Before July 15

If your company has pending ROC filings from past years, this is the best opportunity to clear them. The Companies Compliance Facilitation Scheme 2026 (CCFS-2026) offers a 90% waiver on additional late fees for overdue filings like MGT-7, AOC-4, and ADT-1.

The window is limited: April 15 to July 15, 2026. Here is everything you need to know and the exact steps to take.

What Is CCFS-2026

The Companies Compliance Facilitation Scheme 2026 is an amnesty program by the Ministry of Corporate Affairs (MCA) that allows defaulting companies to file overdue ROC returns at significantly reduced fees. It is similar to previous compliance schemes but with broader coverage and stronger incentives.

Core Benefits

1. 90% waiver on additional late fees for pending ROC filings
2. Immunity from prosecution for filings completed before any adjudication notice is issued
3. Option to convert to dormant company status at 50% of the regular fee
4. Option for voluntary strike-off at 25% of the regular fee

Who Should Use CCFS-2026

The scheme applies to:

• Private limited companies with overdue annual filings
• Public companies with pending ROC returns
• One Person Companies (OPCs) with filing backlogs
• Section 8 companies with outstanding compliance
• Companies that have been marked as "active non-compliant" by MCA

Common overdue filings that qualify:

• MGT-7/MGT-7A (Annual Return)
• AOC-4/AOC-4 CFS (Financial Statements)
• ADT-1 (Auditor Appointment)
• Other mandatory ROC filings

The 90% Fee Waiver Explained

When you file an ROC form late, MCA charges:

• Normal filing fee (depends on the form and company type)
• Additional fee (late fee) calculated based on the delay period

Under CCFS-2026, the additional fee is reduced by 90%. You pay the full normal filing fee plus only 10% of the additional late fee.

Example

A private limited company has not filed AOC-4 for 3 years. The accumulated additional fee might be Rs 36,000 (Rs 100 per day for 360 days per year, approximately).

Under CCFS-2026:

• Normal filing fee: Rs 300 (standard fee for small company)
• Additional fee without scheme: Rs 36,000
• Additional fee with scheme (90% waiver): Rs 3,600
• Total payable: Rs 3,900 instead of Rs 36,300

The savings are substantial, especially for companies with multiple years of pending filings.

Prosecution Immunity

If your company has received show cause notices for non-filing but no adjudication order has been passed yet, filing under CCFS-2026 provides immunity from prosecution for those specific defaults.

Important conditions:

• The filing must be completed before the adjudication notice is issued
• Immunity covers only the specific filings made under the scheme
• Other violations (like fraud or misrepresentation) are not covered
• If an adjudication order has already been passed, the scheme does not apply to that specific filing

Dormant Status Option (STK-1)

If your company is not actively conducting business and you want to keep it registered without full compliance obligations, you can apply for dormant status under CCFS-2026.

How It Works

• File Form STK-1 (Application for Dormant Status)
• Pay 50% of the standard filing fee
• Once approved, the company is classified as "dormant"
• Dormant companies have reduced filing requirements
• You can reactivate the company later when needed

When to Choose Dormant Status

• Your company has no active business operations
• You plan to resume operations in the future
• You want to maintain the company name and CIN
• Full compliance costs are not justified for the current level of activity

Voluntary Strike-Off Option (STK-2)

If your company has no future plans and you want to close it permanently, CCFS-2026 offers voluntary strike-off at reduced fees.

How It Works

• File Form STK-2 (Application for Strike-Off)
• Pay 25% of the standard filing fee
• Clear all pending filings before applying
• Settle all liabilities and distribute remaining assets
• Once struck off, the company ceases to exist as a legal entity

When to Choose Strike-Off

• The company has permanently ceased operations
• There are no outstanding liabilities or legal proceedings
• All assets have been distributed or liquidated
• You do not plan to use this company entity again

Important Warning

Strike-off is permanent. Once completed, the company name, CIN, and all associated registrations are terminated. If you are unsure, choose dormant status instead.

Step-by-Step Process to Use CCFS-2026

Step 1: Identify All Pending Filings

Log in to the MCA portal (mca.gov.in) and check your company's compliance status. List all overdue forms with their due dates and delay periods.

Step 2: Prepare the Financial Statements

For AOC-4 filings, you need audited financial statements for each pending year. If your books of accounts are not up to date, this step may require the most time. Start with the earliest pending year and work forward.

Step 3: Prepare Annual Returns

For MGT-7 filings, compile the annual return data including shareholder details, share transfer records, and board meeting information for each pending year.

Step 4: Get Board Approval

Pass a board resolution authorizing the filing of overdue returns under CCFS-2026. Record the resolution in your board minutes.

Step 5: File on MCA Portal

File each overdue form on the MCA portal during the scheme window (April 15 to July 15, 2026):

1. Log in to MCA V3 portal
2. Select the applicable form (AOC-4, MGT-7, ADT-1, etc.)
3. Fill in the details for the relevant financial year
4. Attach the required documents
5. Pay the reduced fees (normal fee + 10% of additional fee)
6. Submit and note the SRN (Service Request Number)

Step 6: File for Each Pending Year

Repeat the process for every pending year, in chronological order starting from the oldest.

Step 7: Verify Compliance Status

After all filings are processed, check your compliance status on the MCA portal to confirm that all defaults are cleared.

What Happens After July 15, 2026

MCA has explicitly warned that enforcement action will be taken against companies that remain non-compliant after the scheme window closes. This may include:

• Heavy penalties without any fee waiver
• Prosecution proceedings against directors
• Disqualification of directors under Section 164(2)
• Company being marked for strike-off by the Registrar (involuntary)

Director disqualification is particularly serious: disqualified directors cannot be appointed as directors in any company for five years.

Timeline for CCFS-2026

Let Tax Garden Handle Your ROC Compliance

Clearing multiple years of pending filings requires preparing financial statements, compiling annual returns, and filing each form correctly on the MCA portal. Tax Garden's company registration and compliance team handles the entire process, from document preparation to MCA filing, under the CCFS-2026 scheme.

Frequently Asked Questions

Can I file under CCFS-2026 if my company has already received a show cause notice?

Yes, as long as no adjudication order has been passed. Filing under the scheme before adjudication provides immunity from prosecution for that specific default.

Does the 90% waiver apply to the normal filing fee as well?

No. The 90% waiver applies only to the additional (late) fee. The normal filing fee must be paid in full.

Can I apply for dormant status and then reactivate later?

Yes. Dormant companies can be reactivated by filing Form MSC-4 (Application for Active Status) and clearing any compliance requirements. Reactivation is available at any time.

What documents are needed for AOC-4 filing?

Audited financial statements (balance sheet, profit and loss account, notes), auditor's report, board resolution for adoption, and director's report for the relevant financial year.

Can directors who are already disqualified use this scheme?

The scheme allows filing of overdue returns, which may help in the process of seeking restoration of director status. However, the disqualification itself must be addressed separately through the appropriate legal process.