Live update · 31 August 2026: MCA General Circular No. 04/2026 extends CCFS-2026 to 15 September 2026. Read the circular note
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MCA General Circular No. 01/2026, 03/2026 and 04/2026

CCFS 2026: file pending ROC forms at 10% of the additional fee

The Companies Compliance Facilitation Scheme, 2026 closes on 15 September 2026. Until then a defaulting company can clear years of pending AOC-4, MGT-7, MGT-7A and ADT-1 filings by paying the normal fee plus only one-tenth of the accumulated additional fee.

Inactive companies get two more exits in the same window — dormant status under section 455 at half the normal fee, or strike-off through STK-2 at a quarter of the filing fee. This page explains who qualifies, what it costs, what immunity you actually get, and gives you three working tools to decide before the window shuts.

What is CCFS-2026 in one paragraph?

CCFS-2026 is a one-time condonation scheme notified by the Ministry of Corporate Affairs under section 460 read with section 403 of the Companies Act, 2013. Between 15 April 2026 and 15 September 2026, an eligible company can file its pending annual return and financial statement forms by paying the normal filing fee plus only 10% of the additional fee that would otherwise be payable, apply for dormant status in Form MSC-1 at half the normal fee, or apply for strike-off in Form STK-2 at 25% of the filing fee.

10%

Regularise and continue

File every pending MGT-7, MGT-7A, AOC-4 (all variants), ADT-1, FC-3 and FC-4, plus the old 1956 Act forms, at 10% of the additional fee. Normal fee stays payable in full.

50%

Go dormant

A company with no significant accounting transaction can apply under section 455 in Form MSC-1 at half the normal fee and stay on the register with minimal annual compliance.

25%

Close the company

A company that will not be revived can apply for removal of its name in Form STK-2 at 25% of the prescribed filing fee, instead of waiting for the Registrar to act under section 248.

Why this scheme exists: since 1 July 2018 the additional fee for a delayed annual return or financial statement runs at ₹100 per day per form with no upper limit. A company three or four years behind on two forms a year is looking at a six-figure additional fee before any penalty is even considered. CCFS-2026 removes 90% of that number for the companies that use the window.

Tool 1

Eligibility checker

The circular lets every company use the scheme except five specified categories. Answer five questions about your company's current status on the MCA registry.

Is my company eligible for CCFS-2026?

Circular 01/2026, para 5(iii)

Tool 2

CCFS-2026 fee and savings calculator

Add each pending form, pick the financial year it relates to, and the calculator works out the normal fee, the full additional fee under the Companies (Registration Offices and Fees) Rules, 2014, the reduced fee under CCFS-2026 and what the same filing costs once the window closes.

Your pending filings

Government fees only

Exit-route fees in the same window

RouteFormFee during CCFS-2026
Dormant status under section 455MSC-150% of the normal fee for your capital slab
Removal of name (strike-off)STK-225% of the prescribed ₹10,000 fee, i.e. ₹2,500

STK-2 still requires the company to have discharged its liabilities and to have brought overdue annual filings up to the financial year in which it ceased operations. Dormancy and strike-off are not shortcuts around the filings themselves.

How the additional fee is built

  • Annual return and financial statement forms due after 30 June 2018 — ₹100 per day of delay per form, no ceiling.
  • The same forms due on or before 30 June 2018 — a multiple of the normal fee, rising to 12 times beyond 180 days.
  • ADT-1 and other forms — a multiple of the normal fee under Table B of the fee rules, from one time up to 15 days of delay to 12 times beyond 180 days.
  • Under CCFS-2026 — whichever additional fee applies is charged at 10%, calculated by the MCA-21 V3 portal at the payment stage.

What these figures are and are not. The calculator computes statutory fees payable to the Ministry of Corporate Affairs under the Companies (Registration Offices and Fees) Rules, 2014. It does not include professional fees, digital signature costs, stamp duty or any penalty already adjudicated. Actual amounts are confirmed by the MCA-21 V3 portal at the time of filing. Professional charges for the work are consultative and quoted on enquiry.

Tool 3

Which route should this company take?

Regularising, going dormant and striking off lead to very different places. This advisor asks about the company's activity, records and intentions, and points to the route that usually fits, along with the reason.

Route advisor

Continue · Dormant · Strike-off

Forms covered by CCFS-2026

The circular defines "relevant e-forms" exhaustively. Anything outside this list attracts the ordinary additional fee even during the window. Type a form name to filter.

FormWhat it isStatus under CCFS-2026
MGT-7Annual return, section 92Covered
MGT-7AAbridged annual return for OPC and small companiesCovered
AOC-4Filing of financial statements, section 137Covered
AOC-4 CFSConsolidated financial statementsCovered
AOC-4 XBRLFinancial statements in XBRL formatCovered
AOC-4 NBFC (Ind AS)Financial statements of an NBFC under Ind ASCovered
AOC-4 CFS NBFC (Ind AS)Consolidated NBFC statements under Ind ASCovered
ADT-1Notice of auditor appointment, section 139Covered
FC-3Annual accounts and list of places of business of a foreign companyCovered
FC-4Annual return of a foreign companyCovered
Form 20BAnnual return of a company having share capitalCovered
Form 21AAnnual return of a company without share capitalCovered
Form 23ACBalance sheetCovered
Form 23ACAProfit and loss accountCovered
Form 23AC-XBRLBalance sheet in XBRLCovered
Form 23ACA-XBRLProfit and loss account in XBRLCovered
Form 66Compliance certificateCovered
Form 23BAuditor's intimation of appointmentCovered
MSC-1Application for dormant status, section 455Concessional fee, 50%
STK-2Application for removal of nameConcessional fee, 25%
DIR-3 KYC / DIR-3 KYC WebAnnual KYC of directorsNot covered
DPT-3Return of deposits and exempted depositsNot covered
MSME-1Half-yearly return of dues to micro and small enterprisesNot covered
BEN-2Return of significant beneficial ownersNot covered
MGT-14, DIR-12, INC-22, PAS-3, CHG-1Event-based filingsNot covered
Form 11 / Form 8 (LLP)LLP annual return and statement of accountsNot covered — CCFS applies to companies

A separate CCFS application form does not exist. You file the relevant e-form in the ordinary way on MCA-21 V3 and the reduced additional fee is computed at the payment stage while the scheme is live.

What immunity does CCFS-2026 actually give?

This is the part most summaries get wrong. CCFS-2026 is not the blanket immunity of the Companies Fresh Start Scheme, 2020. The protection is conditional and it works differently for the annual filing forms than for the rest.

MGT-7, MGT-7A and the AOC-4 family

These are the section 92 and section 137 filings. Relying on the proviso to section 454(3), the circular says the adjudication proceedings stand concluded and no penalty is leviable where the filing is made under the scheme either:

  • before the adjudicating officer issues a notice, or
  • within thirty days of that notice.

If the thirty days have already run out, or an adjudication order imposing the penalty has already been passed, the penalty liability of the company and its officers stays exactly where it was. Filing under the scheme reduces the fee, not the penalty already crystallised.

ADT-1, FC-3, FC-4 and the 1956 Act forms

For these, immunity is granted against prospective penal action for the delayed filing, subject to two conditions:

  • the form is actually filed under the scheme, and
  • no prosecution has been filed and no adjudication proceeding has been initiated by a show cause notice for that default before you file.

In short, the scheme protects the company that moves first. Once a show cause notice is on record, the fee concession survives but the immunity does not.

Immunity position checker

Proviso to section 454(3)

How the scheme window has moved

Three circulars govern CCFS-2026. Only the closing date has changed; the substance has stayed the same throughout.

24 February 2026 — General Circular No. 01/2026

CCFS-2026 notified under section 460 read with section 403. Window announced as 15 April 2026 to 15 July 2026, with the 10% additional fee, MSC-1 at 50% and STK-2 at 25%.

15 April 2026 — scheme comes into force

Reduced fees start being computed on MCA-21 V3 at the payment stage. No separate application form is prescribed.

8 July 2026 — General Circular No. 03/2026

Closing date moved from 15 July 2026 to 31 August 2026, following restoration and capacity work at the MCA data centre after the fire incident of 5 June 2026 that disrupted MCA21 services during the peak filing period.

31 August 2026 — General Circular No. 04/2026

Closing date further extended to 15 September 2026 in view of representations from stakeholders. All other terms and conditions of CCFS-2026 remain unchanged.

After 15 September 2026

Paragraph 6 of the original circular directs the Registrars of Companies to take necessary action under the Act against companies that did not use the scheme and remain in default.

Read the detailed note on the latest extension: CCFS 2026 extension to 15 September 2026 — MCA update for pending ROC filings.

What sitting out the window costs

The fee concession is only one part of the picture. Continued default under sections 92 and 137 carries penalties in its own right, and a three-year run of default reaches the directors personally.

Penalty under section 92(5)

Failure to file the annual return exposes the company and every officer in default to a penalty of ₹10,000, with a further ₹100 for each day of continuing failure, capped at ₹2,00,000 for the company and ₹50,000 for an officer in default.

Penalty under section 137(3)

Failure to file the financial statements carries ₹10,000 plus ₹100 per day up to ₹2,00,000 on the company, and ₹10,000 plus ₹100 per day up to ₹50,000 on the managing director, chief financial officer or the directors charged with compliance.

Disqualification under section 164(2)

Where a company fails to file financial statements or annual returns for any continuous period of three financial years, its directors become ineligible for reappointment in that company and for appointment in any other company for five years.

Strike-off on the Registrar's motion

Section 248 lets the Registrar remove the name of a company that has not been carrying on business. A company struck off involuntarily leaves the directors with the restoration route under section 252, which is far slower and costlier than STK-2.

Commercial consequences

An MCA master data record showing years of pending filings surfaces in every bank credit review, due diligence, tender pre-qualification, investment process and buyer's checklist. It is usually the first thing a diligence team screenshots.

The fee itself

From 16 September 2026 the additional fee reverts to the full ₹100 per day per form for annual filings, with no upper limit, and continues to accumulate for every further day the form stays unfiled.

Filing under CCFS-2026, step by step

  1. Pull the master data and index of charges from the MCA portal and list every form pending, year by year.
  2. Confirm eligibility against the five exclusions in paragraph 5(iii) of the circular.
  3. Check DSC and DIN status. Expired digital signatures and deactivated DINs are the single commonest reason a scheme filing misses its date.
  4. Verify MCA V3 user mapping for the company and for the professional certifying the forms.
  5. Finalise books, financial statements and audit reports for each pending year separately.
  6. Hold the AGMs for the earlier financial years and adopt the accounts for each respective year, with proper notice, minutes and board reports on record.
  7. File ADT-1 where the auditor's appointment for those years was never intimated.
  8. File AOC-4 first, then MGT-7 or MGT-7A for each year in chronological order.
  9. Confirm the reduced additional fee appears on the payment screen before you pay.
  10. Preserve the challans and SRNs as evidence that the filings were made within the scheme window.

Readiness checklist

0% ready

Timing point. MCA-21 traffic peaks in the final days of any amnesty window, and resubmission requests can consume several working days on their own. Where forms need to be filed for several years, working backwards from 15 September 2026 usually means starting the audit and AGM documentation now rather than the filing.

How we work on CCFS matters

Clearing years of pending ROC filings before 15 September

S.K. Mehta & Co. handles backlog company compliance end to end — reconstructing books for the missing years, completing the statutory audit, preparing board reports and AGM records, and filing the forms on MCA V3 within the scheme window.

  • MCA master data review and pending-form mapping
  • Reconstruction of accounts and finalisation for earlier years
  • Statutory audit and audit report for each pending year
  • AGM documentation, board reports and resolutions
  • AOC-4, MGT-7, MGT-7A and ADT-1 filing on MCA V3
  • MSC-1 dormancy applications and STK-2 strike-off applications
  • Reply to adjudication notices under sections 92 and 137

See the full ROC filing services page

Tell us what is pending

Send the company name and the years outstanding. We will come back with the route, the documents needed and a timeline against the 15 September date.

Send on WhatsApp Call +91-9818167102

Or email alok@skmehta.co.in. Professional charges are consultative and shared after we see the scope.

Frequently asked questions on CCFS-2026

What is the last date to file under CCFS-2026?

15 September 2026. The scheme opened on 15 April 2026 and was originally to close on 15 July 2026. General Circular No. 03/2026 dated 8 July 2026 moved that to 31 August 2026, and General Circular No. 04/2026 dated 31 August 2026 further extended it to 15 September 2026.

Is CCFS-2026 a full waiver of late fees?

No. The normal filing fee remains payable in full. Only the additional fee is reduced, and it is reduced to 10% of what would otherwise be charged, not to nil. The Companies Fresh Start Scheme, 2020 waived the additional fee entirely; CCFS-2026 does not.

Do I need to file a separate application to join the scheme?

No. There is no CCFS application form. You file the pending e-form in the normal way on MCA-21 V3 and the reduced additional fee is computed automatically at the payment stage while the scheme is in force.

Which companies cannot use the scheme?

Five categories are excluded: companies against which the Registrar has already initiated action by final notice for striking off under section 248, companies that have themselves applied for striking off, companies that applied for dormant status under section 455 before the scheme began, companies dissolved under a scheme of amalgamation, and vanishing companies.

Can I file for several past years in one go?

Yes. The scheme is designed for exactly that. All eligible pending years can be regularised within the window, provided the accounts for each year are finalised, audited and adopted at an annual general meeting for that respective year.

AOC-4 needs accounts adopted at an AGM. What if no AGM was held for those years?

The company can hold the annual general meetings now for the earlier financial years, adopt the financial statements for each respective year, and then file the forms under the scheme. The AGM documentation, notices and minutes should reflect the actual dates.

Does the scheme cover LLP filings such as Form 8 and Form 11?

No. CCFS-2026 is notified under the Companies Act, 2013 and applies to companies. LLP annual filings are governed by the Limited Liability Partnership Act, 2008 and are outside this scheme.

Does the scheme cover DIR-3 KYC, DPT-3, MSME-1 or event-based forms?

No. The circular defines the relevant e-forms exhaustively: MGT-7, MGT-7A, the AOC-4 family, ADT-1, FC-3 and FC-4 under the 2013 Act, and Forms 20B, 21A, 23AC, 23ACA, their XBRL versions, Form 66 and Form 23B under the 1956 Act. Everything else attracts the ordinary additional fee.

Will filing under the scheme remove a penalty already imposed?

No. Where an adjudication order imposing a penalty under section 92 or section 137 has already been passed, or where more than thirty days have elapsed since the adjudicating officer's notice, the penalty liability of the company and its officers is unaffected by filing under the scheme.

Does CCFS-2026 reverse a director disqualification under section 164(2)?

The scheme does not itself set aside a disqualification that has already taken effect. Where the three continuous years of default have not yet been completed, bringing the filings up to date within the window prevents the disqualification from being triggered. A disqualification already in force is dealt with separately.

Can a struck-off company use the scheme?

Not directly. A company whose name has been removed from the register has to be restored under section 252 by an order of the National Company Law Tribunal before it can file. Companies against which a final strike-off notice has been issued by the Registrar are among the excluded categories.

Should we wait to see whether MCA extends the date again?

Working to the notified date is the safer course. Two extensions have already been granted, each for specific reasons recorded in the circular, and the current circular says only that the validity stands extended to 15 September 2026. Backlog filings also take real preparation time — audit finalisation, AGM records, DSC renewal and V3 mapping — so the practical deadline is earlier than the legal one.

What happens on 16 September 2026?

The concessional additional fee stops. Annual filing forms revert to ₹100 per day of delay with no ceiling, and paragraph 6 of General Circular No. 01/2026 directs the Registrars to take action under the Act against companies still in default.

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