Companies Compliance Facilitation Scheme 2026 (CCFS) | ROC Amnesty

The Ministry of Corporate Affairs (MCA) has introduced the Companies Compliance Facilitation Scheme 2026 (CCFS-2026), a one-time compliance window designed to give defaulting companies a genuine chance to clear their pending ROC filings at a fraction of the normal cost.

If your company has not filed annual returns or financial statements for one year or several, this scheme reduces your accumulated late fee burden by 90%. You pay only 10% of the additional fees that would otherwise apply. The scheme also provides a concessional route for inactive companies to either declare dormancy or formally close, options that were not available under the earlier CFSS 2020.

This is a time-limited opportunity. The scheme opened on April 15, 2026 and closes on July 15, 2026. After that date, full penalties resume and the ROC is expected to initiate enforcement actions against outstanding defaulters.

Why Has MCA Introduced the CCFS Scheme?

Since July 2018, the Companies Act prescribes an additional late fee of ₹100 per day for delayed annual filings, with no upper cap. For companies that have missed filings for multiple years, this creates a penalty burden that can easily run into lakhs, making voluntary compliance financially impossible.

MCA introduced CCFS 2026 through General Circular No. 01/2026 to address this exact problem. The primary objectives are:

• Reduce the financial burden of accumulated late fees on MSMEs, startups, and small private companies.
• Improve the accuracy of the corporate registry by bringing non-compliant companies back into the filing system.
• Provide a clean-exit pathway for dormant and defunct companies through concessional dormancy and strike-off routes.

This is the second such scheme after CFSS 2020 (launched during the COVID-19 period). The 2026 version has broader coverage and includes options that CFSS 2020 did not offer.

Key Takeaways of CCFS 2026

The scheme primarily targets companies that are:

• In default, not filing annual returns for one or more past financial years
• Not submitting financial statements (AOC-4) to the ROC
• Inactive but still registered and accumulating compliance obligations
• Looking to formally close (strike-off) or pause operations (dormant status)
• Unable to clear past defaults due to the heavy additional fees involved

Scheme Period - When Can You File?

The CCFS 2026 window is open from April 15, 2026, to July 15, 2026, a period of exactly three months.

All eligible pending forms filed within this window will attract the concessional fee structure. Forms filed after July 15, 2026, will be subject to standard additional fees and late filing penalties with no concession.

Practical note: MCA filing portals are frequently congested in the final weeks before scheme deadlines. Filing early is advisable; last-minute rejections and correction cycles can push you past the deadline.

Who Can Avail CCFS 2026? - Eligibility at a Glance

All companies registered under the Companies Act, 2013, are eligible, except those in the excluded categories listed below.

 

Note: The scheme does not prescribe a positive eligibility criterion; it defines a negative list. Any company not falling in the excluded categories can avail the benefits.

Applicability and Financial Incentive

Forms Covered Under CCFS 2026

The following e-forms are covered under the scheme. This list includes both forms under the Companies Act, 2013 and eligible forms under the erstwhile Companies Act, 1956, meaning even very old pending filings can be regularised.

CCFS 2026 vs CFSS 2020 - What Has Changed?

Many directors and CAs are searching for 'CFSS 2020' when they mean CCFS 2026. They are related but distinct schemes. Here is a direct comparison of what is new this time:

The most significant additions in CCFS 2026 are the dormancy and strike-off routes at concessional rates, pathways that were completely absent from CFSS 2020. If you missed CFSS 2020, this scheme provides a second and likely final opportunity to clean up your company's compliance record without catastrophic costs.

How Much Can You Actually Save Under CCFS 2026?

The majority of company directors want to know one specific thing: what does this actually cost me in practice?

Under the Companies (Registration Offices and Fees) Rules, 2014, the additional fee for delayed annual filings is ₹100 per day with no ceiling. For a company that has not filed AOC-4 and MGT-7 for three years, the total additional fees can reach ₹73,000 to over ₹1,00,000, before accounting for legal notices or prosecution costs.

Under CCFS 2026, you pay just 10% of those additional fees. Here is what that looks like in practice: 

 

These figures relate to additional fees only. Normal government filing fees still apply in full. Actual amounts vary based on paid-up capital and the specific forms involved; a CA or CS should calculate your exact liability before filing.

What Does Prosecution Immunity Mean for Your Directors?

Annual filing defaults carry personal consequences for directors, not just the company. Under the Companies Act, directors of a defaulting company can face:

• Adjudication notices from the ROC
• Court proceedings and personal financial penalties for wilful non-compliance
• Director disqualification under Section 164(2), which bars a director from appointment in any company for five years

Under CCFS 2026, completing your pending filings within the scheme period provides immunity from these prosecution actions for the covered defaults. Once you file and pay the reduced fees, the historical non-compliance is regularised, and no adjudication notice will be issued for the same defaults.

This immunity is conditional; it applies only to filings made during the scheme window and only for defaults covered by the scheme. Any adjudication order that has already been passed before the scheme's inception remains payable.

Step-by-Step Process to File Under CCFS 2026

MCA has not prescribed a separate registration form for CCFS 2026. You file directly through the standard MCA portal using the relevant forms. Here is the process:

1. Identify All Pending Forms- Review your company's filing history on the MCA portal. List all outstanding ADT-1, AOC-4, and MGT-7 forms for every financial year since incorporation or since the last filed year.
2. Verify Scheme Eligibility- Confirm your company does not fall in the excluded categories (strike-off already filed, dormant status already applied for, amalgamation proceedings ongoing, or vanishing company status).
3. Audit Financials and Draft Board Resolutions- Ensure all financial statements are audited up to the relevant date. Board resolutions approving the financial statements and annual returns must be in place before filing.
4. File Forms on MCA Portal and Pay Fees- Log in to mca.gov.in, file each pending form, and pay normal fees plus 10% of the applicable additional fees. For dormancy, pay 50% of normal fees. For strike-off via STK-2, pay 25% of normal fees.
5. Confirm Payment and Save Challan Copies- After each filing, download the SRN acknowledgement and challan receipt. These are your evidence of compliance under the scheme and proof of immunity from further action on those defaults.

What Happens If You Miss the July 15, 2026 Deadline?

Missing this deadline does not simply mean losing the fee discount. The consequences escalate quickly once the scheme closes.

Under General Circular No. 01/2026, the Registrar of Companies (ROC) will initiate enforcement actions against all outstanding defaulters after July 15, 2026. Based on past precedent following similar schemes, the likely consequences include:

• Full additional late fees at ₹100 per day, with no ceiling, on all outstanding forms
• Director disqualification under Section 164(2) of the Companies Act, directors cannot be appointed in any company for five years
• ROC-initiated strike-off proceedings, which can result in the company being forcibly removed from the register
• Personal liability on the directors for prolonged and wilful non-compliance
• Prosecution notices and adjudication orders that cannot be reversed by subsequent compliance

After July 15, the company loses all the leverage this scheme provides. Voluntary compliance at a deeply reduced cost is always preferable to enforcement at full cost.

How JustStart Can Help You File Under CCFS 2026

Filing multiple years of pending AOC-4, MGT-7, and ADT-1 forms within a 90-day window requires careful preparation, audited financials, board resolutions, correct fee calculation, and sequenced filing on the MCA portal. Errors at the filing stage can result in rejection, loss of time, and, in the worst case, missing the scheme window altogether

JustStart's team of practising Company Secretaries and Chartered Accountants can:

• Conduct a complete compliance audit to identify all pending forms across financial years
• Calculate the exact fees payable under CCFS 2026 for your specific company
• Prepare and file all required forms on the MCA portal within the scheme period
• Provide the necessary board resolution and documentation support
• Ensure you receive and retain all challan receipts and acknowledgements as proof of compliance

The CCFS 2026 window closes on July 15, 2026. The sooner you act, the more time is available to handle any filing rejections or corrections. Contact JustStart today to begin your compliance audit. 

Frequently Asked Questions (FAQs)

Q1. What is the CCFS 2026 scheme?

The Companies Compliance Facilitation Scheme 2026 (CCFS-2026) is a one-time amnesty programme introduced by the Ministry of Corporate Affairs under General Circular No. 01/2026 dated February 24, 2026. It allows defaulting companies to file pending ROC documents, including annual returns and financial statements, by paying only 10% of the accumulated additional late fees, effectively providing a 90% waiver on delayed filing penalties.

Q2. What is the last date to file under CCFS 2026?

The scheme is operational from April 15, 2026, to July 15, 2026. Forms filed after July 15, 2026, will not receive any concession and will attract full additional fees and penalties.

Q3. Which forms can be filed under CCFS 2026?

Eligible forms include ADT-1 (Auditor Appointment), AOC-4 and AOC-4 CFS (Financial Statements), MGT-7 and MGT-7A (Annual Returns), AOC-4 XBRL (XBRL Financial Statements), FC-3 and FC-4 (Foreign Company filings), and various forms under the erstwhile Companies Act, 1956. MCA's circular lists the complete set of eligible forms.

Q4. How much do I actually pay under CCFS 2026?

You pay the normal government filing fee in full, plus only 10% of the additional late fees that would otherwise be payable on account of the delay. For dormancy filings (Form MSC-1), you pay 50% of the normal fees. For strike-off filings (Form STK-2), you pay 25% of the normal fees.

Q5. Is CCFS 2026 applicable to LLPs?

No. CCFS 2026 applies only to companies registered under the Companies Act, 2013 and the erstwhile Companies Act, 1956. Limited Liability Partnerships (LLPs) are not covered; the scheme's circular and the list of eligible forms do not include any LLP-specific forms.

Q6. Which companies are NOT eligible for CCFS 2026?

The following are excluded: companies against which a final strike-off notice under Section 248 has already been initiated; companies that have already filed an application for strike-off; companies that had already applied for dormant status before the scheme commenced on April 15, 2026; companies that have been dissolved under an amalgamation scheme; and vanishing companies (companies not traceable at their registered address).

Q7. What is the difference between CCFS 2026 and CFSS 2020?

CFSS 2020 was launched during the COVID period and offered 100% waiver on additional fees, but did not cover dormancy or strike-off options. CCFS 2026 provides a 90% waiver (10% additional fees payable), and importantly, extends the benefit to dormancy filings (50% of normal fees via MSC-1) and formal company closure (25% of normal fees via STK-2). Foreign company forms FC-3 and FC-4 are also included in CCFS 2026, which were absent from CFSS 2020.

Q8. What happens if my company does not file before July 15, 2026?

After the scheme closes, the ROC will initiate enforcement actions against all outstanding defaulters. This may include full late fees with no ceiling, director disqualification under Section 164(2) for five years, strike-off proceedings initiated by the ROC, and prosecution notices. The scheme provides a significantly cheaper and faster path to compliance; missing it will result in substantially higher costs and legal consequences.