Filing Overdue ROC Returns After CCFS 2026 Closed
The Ministry of Corporate Affairs CCFS 2026 scheme let defaulting companies file overdue MGT-7, AOC-4, ADT-1 and other ROC returns by paying only 10% of the late fees. The window ran from April 15 to September 15, 2026 and is now closed. Those forms are still overdue and now carry the full additional fee, so Tax Garden prepares your financial statements, reconciles pending years, and files everything on the MCA portal to stop the daily fee from growing.
90%
waiver on additional late fees while the window was open
Apr 15 to Sep 15
one-time window under MCA Circular 01/2026, extended by 03/2026 and 04/2026, now closed
All forms
MGT-7, AOC-4, ADT-1, DIR-12, INC-22 and more
Savings calculator
3 years pending AOC-4
What you pay now
Normal + full late fee
With CCFS 2026 (closed Sep 15)
Normal fee + 10% of late fee
Saving missed
Per pending ROC form set
Example of what a small private limited company would have saved while CCFS 2026 was open. The waiver no longer applies to filings made after September 15, 2026.
CCFS 2026 closed on September 15, 2026. The MCA has warned of enforcement action, Active Non-Compliant tagging, and director disqualification for companies that are still non-compliant.
MCA Circular 01/2026
What is the Companies Compliance Facilitation Scheme 2026?
CCFS 2026 was a one-time amnesty announced by the Ministry of Corporate Affairs on February 24, 2026. It let defaulting companies clear overdue annual filings and secretarial forms on the MCA portal at significantly reduced fees, with immunity from prosecution for past defaults filed under the scheme. The window closed on September 15, 2026, so these concessions no longer apply. Pending forms still have to be filed, now at the full additional fee. See how we handle ROC compliance end-to-end, see our ROC annual compliance service for overdue MGT-7 and AOC-4 filings, or get help with your overdue ROC filings.
90% waiver on late fees
Companies that filed inside the window paid only 10% of the additional fee accumulated on overdue ROC filings. Normal filing fees still applied.
Immunity from prosecution
Filings completed inside the window, before an adjudication notice was issued, were protected from prosecution for those specific defaults.
Dormant status at 50% fees
Companies that were not operating could convert to dormant status at half the regular fee while the scheme ran.
Voluntary strike-off at 25% fees
Companies closing down could file STK-2 at a quarter of the standard filing fee while the scheme ran.
Eligibility
Which companies could file under CCFS 2026?
Any company with pending ROC filings from previous financial years, and no adjudication order passed against those specific defaults, could use the scheme. Dormant and inactive companies qualified too. The window has closed, but those same companies still need to file, and the additional fee grows every day the forms stay pending.
- Private limited companies with overdue annual filings
- Public limited companies with pending ROC returns
- One Person Companies (OPCs) with filing backlogs
- Section 8 (non-profit) companies with outstanding compliance
- Companies flagged as 'active non-compliant' on the MCA portal
- Companies that want to move to dormant status or strike off cleanly
Coverage
Forms covered under CCFS 2026
The scheme covered all major annual and event-based ROC filings. These are the same forms our clients are still clearing, now at the regular additional fee.
| Form | Purpose | Typical late fee (without scheme) |
|---|---|---|
| MGT-7 | Annual Return (companies with share capital) | Rs 12,000+ / year |
| MGT-7A | Annual Return (small / One Person Companies) | Rs 6,000+ / year |
| AOC-4 | Financial Statements | Rs 12,000+ / year |
| AOC-4 CFS | Consolidated Financial Statements | Rs 12,000+ / year |
| ADT-1 | Auditor Appointment | Rs 3,600+ / year |
| DIR-12, INC-22, MGT-14 | Director, registered office, and board resolution filings | Varies by form |
Late fees are approximate and depend on delay period, company type, and authorised capital. Actual numbers are confirmed after an MCA master data check.
How we file for you
End-to-end ROC catch-up filing in 5 steps
From reconstructing missing financials to uploading final forms on the MCA portal, we handle every step. You review and approve; we do the rest.
Free 15-minute diagnostic call
We pull your company master data from MCA, confirm how many years of filings are pending, and give you a fixed total-cost estimate on the same call.
Finalise accounts and auditor sign-off
Our team prepares balance sheets, P&L, and directors' reports for each defaulting year. If your auditor is hard to reach, we coordinate signatures for you.
File overdue forms in correct order
ADT-1 first, then AOC-4, then MGT-7 for each year. We run pre-scrutiny checks so no SRN gets rejected and no fee gets wasted.
Pay reduced fees on MCA portal
You pay only 10% of the additional late fee along with the normal filing fee. We share the challan and SRN for every form.
Receive clean compliance certificate
Once the ROC accepts all forms, your company status moves back to 'Active Compliant'. We hand over a compliance dossier you can show to banks and investors.
No credit card. No commitment. We tell you the total cost before you pay anything.
Worked example
What CCFS 2026 saved: 3 years of AOC-4 + MGT-7 defaults
This is what a typical small private limited company with three years of pending AOC-4 and MGT-7 filings would have paid under CCFS 2026 versus the regular fee structure. The scheme closed on September 15, 2026, so the regular path is now the only one available. It is shown here so you can see what the delay costs.
- Additional (late) fee without scheme: approximately Rs 100 per day per form, accumulating to Rs 72,000+ across both forms.
- Under CCFS 2026 the additional fee was capped at 10%: around Rs 7,200 total. That cap is no longer available.
- Normal filing fees and Tax Garden's service fee are transparent and confirmed before you commit.
Regular path (applies now)
Normal fee + full late fee, 3 years
Rs 72,600
Under CCFS 2026 (window closed)
Normal fee + 10% of late fee, 3 years
Rs 7,800
Missed saving
Per company, window now closed
Rs 64,800
Illustrative. Exact liability depends on paid-up capital, exact delay days, and form mix. Final numbers are confirmed from MCA master data.
Why founders choose Tax Garden
Cleanup that holds up under due diligence
Named company secretary assigned
You work with one specific CS throughout the filing cycle. No ticket queues, no handoffs.
Pre-scrutiny on every form
We run MCA pre-scrutiny checks before paying fees so rejected SRNs do not eat into your scheme budget.
Investor-ready dossier
At the end, you get a clean compliance dossier with challans, SRNs, and the ROC certificate ready to share with banks and investors.
FAQs
Common questions about CCFS 2026
What is the CCFS 2026 scheme?
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The Companies Compliance Facilitation Scheme 2026 was an amnesty program announced by the Ministry of Corporate Affairs under General Circular No. 01/2026. It let defaulting companies clear overdue ROC returns with a 90% waiver on additional late fees. The window ran from April 15, 2026 to September 15, 2026 and is now closed.
How much can I actually save under CCFS 2026?
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The window has closed, so the waiver is no longer available. While it ran, a small private limited company with 3 years of overdue AOC-4 would typically have paid about Rs 3,900 under CCFS 2026 versus Rs 36,300 without the scheme. Overdue filings made from September 16, 2026 onward attract the full additional fee of Rs 100 per day per form.
Which forms are covered under the scheme?
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The scheme covered MGT-7, MGT-7A, AOC-4, AOC-4 CFS, ADT-1, and most other mandatory ROC filings, including DIR-12, INC-22, and MGT-14. It did not cover forms related to fraud, misrepresentation, or already-adjudicated defaults. These same forms still have to be filed now, at full additional fees.
I have received a notice from the MCA. Can I still file under CCFS 2026?
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No. CCFS 2026 closed on September 15, 2026, so the prosecution immunity it offered is no longer available for new filings. If you have a show cause notice, respond within the stated period and file the pending forms at the normal additional fee. Once an adjudication order is passed, penalties are decided under Section 454 and have to be paid as ordered.
Was the CCFS 2026 deadline extended?
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Yes, twice. The original cutoff of July 15, 2026 was extended to August 31, 2026 by General Circular 03/2026, then to September 15, 2026 by General Circular 04/2026 dated August 31, 2026. No further extension was announced, so the scheme closed on September 15, 2026. MCA has warned of enforcement action, Active Non-Compliant tagging, and director disqualification for remaining non-filers.
Do directors need to do DIR-3 KYC separately?
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Yes. DIR-3 KYC is a separate requirement for every DIN holder (from 31 March 2026, once every three financial years by 30 June) and was never covered under CCFS 2026. We bundle KYC filings with your ROC catch-up work so your directors end up fully compliant in one go.
Go deeper
Detailed CCFS 2026 reads
Guide
CCFS 2026 Amnesty Scheme: How the 90% Waiver Worked
Detailed walkthrough of MCA Circular 01/2026 covering eligible forms, fee calculation, dormant company options, and the full filing process.
Read guidePlaybook
Clearing Pending ROC Filings With CCFS-2026
Step-by-step playbook for defaulting companies: dormant status, voluntary strike-off, prosecution immunity, and exact filing order.
Read playbookMissed CCFS 2026? Let us clear the backlog, end-to-end
Book a free review. We will pull your MCA master data, list every pending form, calculate the additional fee now due, and quote a fixed fee on the same call. No follow-up haggling.
Transparent fees confirmed upfront. No surprise charges after filing starts.