“Our company was incorporated five years ago. We missed a few annual filings, then a few more. Now the penalties are in lakhs — we don’t even know where to begin.”
If this sounds familiar, you are not alone. Thousands of Indian companies — startups, small businesses, and even otherwise well-run private limited companies — have accumulated years of pending ROC (Registrar of Companies) filings. The reasons vary: cash flow pressure, shifting priorities, lack of awareness, or simply the belief that it can be sorted out later.
The Ministry of Corporate Affairs (MCA) has now opened a rare, time-bound window to fix this — at a fraction of the usual cost. It is called the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026), and if your company has any pending filings, this is the most important compliance update of this year.
What Is CCFS-2026?
The Companies Compliance Facilitation Scheme, 2026 is a one-time relief initiative introduced by the MCA vide General Circular No. 01/2026 dated February 24, 2026. Think of it as a government-issued amnesty for companies that have fallen behind on their statutory filings with the ROC.
Under normal circumstances, a company that misses its annual return or financial statement deadline is charged an additional fee of ₹100 per day — with no upper cap. This means that a company which has not filed for even three years could owe late fees running into several lakhs, just in penalties, before any actual fines or legal action.
CCFS-2026 allows such companies to come forward, clear their backlogs, and regularise their ROC compliance — paying only 10% of the additional fees that would otherwise be due. The remaining 90% is, in effect, waived.
The scheme is operational from 15 April 2026 to 15 July 2026 — a three-month window. It does not require a separate application or registration. Eligible companies simply file the pending forms on the MCA-21 portal within this period.
Who Can Benefit?
CCFS-2026 is primarily designed for:
- Private limited companies with one or more years of missed annual filings
- One Person Companies (OPCs) with pending returns
- MSMEs and startups that have been operationally active but compliance-deficient
- Inactive companies that are not yet formally struck off or dissolved
- Companies where directors are at risk of disqualification due to non-filing under Section 164(2) of the Companies Act, 2013
A simple example: A private limited company incorporated in 2020 that has not filed its Annual Return (MGT-7) or Financial Statements (AOC-4) for the last three financial years would normally owe additional fees in the range of ₹3–5 lakhs or more, just in late charges. Under CCFS-2026, the same company can clear all three years by paying approximately 10% of that amount.
Who Is Excluded?
The scheme does not apply to:
- Companies that have already received a final strike-off notice from the ROC
- Companies that applied for dormancy or strike-off before the scheme commenced
- Companies that have already been dissolved or wound up
- Companies classified as “vanishing companies” by the MCA
Key Benefits at a Glance
| Situation | Normal Cost | Under CCFS-2026 |
|---|---|---|
| Pending annual filings (MGT-7, AOC-4) | 100% additional fee (₹100/day, uncapped) | 10% of additional fee |
| Applying for Dormant Status (MSC-1) | 100% of normal filing fee | 50% of normal filing fee |
| Voluntary Strike-Off (STK-2) | 100% of filing fee | 25% of filing fee |
Beyond the fee relief, the scheme also provides immunity from penalty proceedings under certain provisions of the Companies Act, 2013, for filings made during the scheme window — subject to the condition that no adjudication order has already been issued by the ROC.
Which Forms Are Covered?
The following are the key e-forms covered under CCFS-2026:
- MGT-7 / MGT-7A — Annual Return
- AOC-4 / AOC-4 XBRL / AOC-4 CFS — Financial Statements
- ADT-1 — Auditor Appointment
- FC-3 / FC-4 — Forms applicable to foreign companies with Indian operations
- Certain forms under the Companies Act, 1956 (for very old pending filings)
Note: Forms such as INC-20A (Declaration for Commencement of Business) and DPT-3 (Return of Deposits) are not covered under CCFS-2026 and must be filed separately under the regular process.
Important Dates — Mark Your Calendar
| Event | Date |
|---|---|
| MCA Circular Issued | 24 February 2026 |
| Scheme Becomes Effective | 15 April 2026 |
| Last Date to File Under Scheme | 15 July 2026 |
| Post-Scheme Enforcement Begins | After 15 July 2026 |
This window is strictly time-bound. There are no extensions expected. The MCA has explicitly stated that post July 15, 2026, all Registrars of Companies will initiate enforcement action against non-compliant companies.
How Does It Work — Practically Speaking
Here is a simple, step-by-step understanding of how the process works:
Step 1 — Identify Pending Filings Log in to the MCA-21 portal and check the filing history of your company. Note which annual returns and financial statements are still pending and for which financial years.
Step 2 — Prepare the Required Documents Gather the relevant financial statements, board resolutions, and other supporting documents needed for each form. In many cases, documents for past years will need to be compiled from older records.
Step 3 — Calculate the Applicable Fee The total additional fee payable for each delayed form is calculated based on the number of days of delay. Under CCFS-2026, only 10% of this amount is payable. The MCA portal typically calculates this automatically at the time of filing.
Step 4 — File on MCA-21 Portal Submit the forms online during the scheme period (April 15 – July 15, 2026). No separate application is required for the scheme. The fee concession is automatically applied.
Step 5 — Save Your SRNs After each submission, the portal generates a Service Request Number (SRN). These SRNs serve as proof of filing and should be preserved carefully.
Step 6 — Confirm Acknowledgement The ROC typically updates the company’s status on the MCA registry within 7–15 working days. Once updated, the company’s filing record will reflect a compliant status.
Risks of Not Acting Before July 15, 2026
The MCA circular is unambiguous: after the scheme closes, the ROC will take action against all companies that remain in default. This is not a theoretical risk — it is a stated regulatory commitment.
Here is what non-compliance can lead to:
- Adjudication notices under Section 454 — resulting in monetary penalties on both the company and its directors personally
- Director Disqualification under Section 164(2) — a director of a company that has not filed annual returns or financial statements for three consecutive financial years is automatically disqualified and cannot serve as a director in any company for five years
- Prosecution proceedings in serious cases
- Complications in fundraising — investors and lenders routinely check MCA filing status; multiple years of non-filing is a significant red flag in due diligence
- Inability to close or exit the company — a non-compliant company cannot easily be struck off voluntarily
The cost of inaction significantly outweighs the cost of filing now.
A Note on Professional Assistance
While the scheme process itself is straightforward in concept, the actual execution — particularly for companies with multiple years of missed filings — can involve several layers of complexity. This includes:
- Reconstructing past financial records and preparing compliant financial statements
- Ensuring consistency across multiple years of filings
- Determining correct fee calculations
- Evaluating whether dormancy or strike-off may be a better route than continued compliance
- Assessing exposure in cases where adjudication notices may already have been issued
For matters of this nature, companies generally work with practising Chartered Accountants or Company Secretaries who are familiar with MCA processes and the requirements of the Companies Act, 2013. Professional guidance helps avoid errors, re-submissions, and inadvertent non-compliance with scheme conditions.
Frequently Asked Questions (FAQs)
Q1. Our company has not filed returns for 5 years. Can we still avail the CCFS-2026 benefit?
Yes. The scheme covers all pending annual filings regardless of how many years are outstanding, provided the company has not already been struck off or dissolved, and no final strike-off notice has been issued by the ROC. All pending years can be cleared under the scheme by paying 10% of the applicable additional fees.
Q2. We received a notice from the ROC last year. Are we still eligible?
This depends on the nature and stage of the notice. If an adjudication order imposing penalties has already been passed, the liability under that order remains and the scheme does not override it. However, if the notice was merely an advisory or reminder (and no order has been passed), the company may still be eligible. It is advisable to seek professional guidance to assess the specific situation before proceeding.
Closing Note
CCFS-2026 is a genuinely rare opportunity for companies to restore their compliance standing at a substantially reduced cost. Schemes of this nature are not introduced every year, and the post-scheme enforcement environment is expected to be significantly stricter.
Whether your company has missed one year of filings or several, the prudent step is to use this three-month window to assess where you stand and take corrective action.
Compliance is not just a legal obligation — it is a business asset. A clean ROC record supports fundraising, banking relationships, contract credibility, and the ability to exit or restructure when needed.
This article is published purely for educational and awareness purposes. It does not constitute legal advice or a professional opinion on any specific matter. Readers are encouraged to review the original MCA Circular No. 01/2026 and consult a qualified professional for guidance specific to their company’s circumstances.
© 2026 Chopda & Kataria, Chartered Accountants | www.chopdakataria.com
