Published by VirtualCA (K P N R & Co.) | Last updated: May 2026
The Problem Every Director Quietly Carries
If you are a director of a private limited company, an OPC, or a small company that has fallen behind on ROC filings, you already know the feeling. The MCA portal becomes something you avoid opening. Late fee calculations grow heavier each month. At ₹100 per day per form, a company that has not filed for three or four years can easily be staring at additional fees of ₹3 to ₹7 lakhs — sometimes more.
Most directors we meet at VirtualCA did not intentionally default. Operations got busy. The accountant left. Funding dried up. The business paused. And by the time they checked back, the penalty meter had crossed a number that made compliance feel impossible.
The Ministry of Corporate Affairs has finally acknowledged this reality. Through General Circular No. 01/2026 dated 24th February 2026, the MCA has introduced the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) — a one-time, three-month window to regularise pending filings at a fraction of the usual cost.
This blog walks you through what the scheme covers, who can use it, how much you actually save, and the practical steps to take before the window closes on 15th July 2026.
What is CCFS-2026?
CCFS-2026 is a temporary compliance amnesty notified by the MCA under the combined authority of Section 460 read with Section 403 of the Companies Act, 2013. Section 460 empowers the Central Government to condone delays in filing documents with the Registrar; Section 403 governs the fees payable for those filings. Using these powers, the MCA has created a window during which defaulting companies can clear their backlog by paying:
- Normal filing fees in full, plus
- Only 10% of the additional (late) fees that would otherwise apply
The scheme is effective from 15th April 2026 to 15th July 2026 — exactly three months. After that, the standard ₹100-per-day late fee applies again, and the Registrars have been specifically directed to initiate enforcement action against companies that did not use the window.
This is not the first such scheme — CFSS 2020 and earlier amnesty schemes have come before it — but CCFS-2026 is broader. It does not just reduce filing fees; it also offers concessional routes to dormant status (under Section 455) and strike-off (under Section 248).
The Three Routes Available Under CCFS-2026
Depending on what you want to do with your company, the scheme offers three distinct pathways. Choosing the right one matters, because each has different consequences for the future of the entity.
Route 1: Regularise and Continue Operations
For companies that are active or intend to remain active, this is the most common route. You file all pending annual filing forms (AOC-4, MGT-7/MGT-7A, ADT-1, and others) and pay the normal fee plus only 10% of the accumulated late fee. Once filed, immunity from prosecution applies for the defaults covered under the scheme.
Example: A private limited company that has not filed AOC-4 and MGT-7 for FY 2020-21 through FY 2024-25 may have accumulated late fees of around ₹7,30,000 (5 years × 365 days × ₹200 per day across both forms, roughly). Under CCFS-2026, the company pays the normal filing fees plus approximately ₹73,000 — saving over ₹6.5 lakhs.
Route 2: Apply for Dormant Status (Form MSC-1)
If your company has had no significant accounting transactions for at least the last two financial years and you want to keep the entity alive without operational activity, dormant status under Section 455 is the cleanest option. Under CCFS-2026, Form MSC-1 can be filed at 50% of the normal fee.
This route is useful for holding companies, project SPVs that are between projects, or businesses pausing for a few years.
Route 3: Strike Off the Company (Form STK-2)
If the company is genuinely defunct and you want to exit the registry, Form STK-2 can be filed at just 25% of the normal fee under the scheme. Note that before filing STK-2, you must still bring all annual filings up to date until the date the company ceased operations — Rule 4 of the Companies (Removal of Names) Rules, 2016 still applies.
Forms Covered Under the Scheme
The scheme covers the following e-forms commonly used for annual compliance:
- AOC-4, AOC-4 CFS, AOC-4 NBFC (Ind AS), AOC-4 CFS NBFC (Ind AS), AOC-4 (XBRL) — Financial Statements
- MGT-7, MGT-7A — Annual Return
- ADT-1 — Auditor Appointment Intimation
- FC-3, FC-4 — Annual filings for foreign companies operating in India
- MSC-1 — Application for Dormant Status
- STK-2 — Application for Strike-Off
Certain legacy forms from the Companies Act, 1956 are also covered, which helps companies with very old historical defaults.
What is NOT covered: Event-based forms like SH-7 (increase in authorised capital), PAS-3 (return of allotment), and similar transactional filings remain outside the scheme. Also, the scheme does not apply to LLPs — the language of the circular refers only to companies.
Who is Eligible?
The MCA has not prescribed positive eligibility criteria. Instead, the scheme works on a negative list — every company is eligible except those falling in the excluded categories. The excluded categories are:
- Companies against which a final notice under Section 248(1) for striking off has already been issued by the Registrar
- Companies that have already filed Form STK-2 for voluntary strike-off before the scheme commenced
- Companies that have already applied for dormant status under Section 455 before 15th April 2026
- Companies dissolved through a scheme of amalgamation without winding up
- Companies that have already received a notice of adjudication under Section 454(3) where 30 days have elapsed
A common doubt: "Our defaults are too old — say from FY 2016 — can we still use the scheme?" In most cases, yes. The scheme does not put an outer time limit on how old the defaults can be. As long as the company is not in one of the excluded categories above, even decade-old backlogs can be regularised.
What Happens If You Miss the Window?
This is the part most directors underestimate. The circular explicitly directs the Registrars of Companies to take "necessary action under the Act" against companies that remain in default after 15th July 2026. In practice, this means:
- Adjudication proceedings under Section 454, with penalties on the company and on every officer in default
- Director disqualification under Section 164(2) for directors of companies that have not filed financial statements or annual returns for any continuous period of three financial years — the disqualification extends to all other companies the director is on the board of
- Strike-off action initiated suo moto by the ROC, leaving the company in legal limbo and the directors carrying the residual liabilities
The 90% waiver on additional fees evaporates the moment the scheme ends. From 16th July 2026, the meter goes back to ₹100 per day per form, with no upper cap.
Practical Steps: What to Do Now
Based on the cases we are handling at VirtualCA right now, here is the sequence we recommend:
Step 1: Pull a master list of pending filings. Log into the MCA portal under the company's master data and identify every annual filing that is overdue. Do not rely on memory — pull the actual portal data.
Step 2: Decide the route. Is the company active and continuing? Going dormant? Closing down? This decision changes which forms you file and the fee calculation.
Step 3: Reconstruct the financials. For companies with 3 to 5 years of pending filings, the bulk of the work is not the form itself — it is preparing audited financial statements and board reports for each year. This needs an auditor, board resolutions for each year, and the actual books.
Step 4: Calculate the savings before committing. A quick calculation of the late fee savings against the cost of audit and professional fees helps you decide whether the scheme is worth pursuing or whether strike-off is the more sensible exit.
Step 5: File well before 15th July. Last-minute rushes invariably cause MCA portal congestion, DSC issues, and rejected filings. We are advising our clients to target completion by 30th June 2026 to leave a buffer.
Where VirtualCA Can Help
At VirtualCA, we are currently assisting several clients across Hyderabad and other cities through CCFS-2026. The work typically involves:
- Reviewing the company's MCA master data and pending forms
- Reconstructing books and preparing audited financials for the backlog years
- Conducting board meetings and preparing the necessary resolutions
- Filing AOC-4, MGT-7, ADT-1, and other applicable forms under the scheme
- Where appropriate, advising on whether dormancy or strike-off is a better exit than full regularisation
- Coordinating DSC renewals, DIN-KYC, and other prerequisites
If your company has pending ROC filings — whether one year or seven years' worth — the next eight weeks are the most cost-effective window you will get for a long time. The earlier you start, the cleaner the process.
Final Thought
Compliance amnesty schemes do not come around often. The last comparable window — CFSS 2020 — was driven by the pandemic. CCFS-2026 has been launched in calmer circumstances, which suggests that the next such opportunity may not come for several years. Directors who use the scheme close out years of stress for a fraction of the cost. Directors who wait usually regret it.
The window closes on 15th July 2026. The work to prepare the backlog filings takes weeks, not days. The right time to start is now.
To discuss your company's situation with our team, get in touch with VirtualCA.
Disclaimer: This blog is for informational purposes and reflects the position of CCFS-2026 as notified under General Circular No. 01/2026 dated 24th February 2026. It is not a substitute for professional advice. The scheme's terms, eligibility, and applicable forms should be verified against the latest MCA notifications before action.
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