The Ministry of Corporate Affairs notified the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) via General Circular No. 01/2026 dated 24 February 2026. The scheme opened on 15 April 2026 and remains in force until 15 July 2026 — a twelve-week amnesty window for companies that have accumulated ROC filing defaults.
For Chartered Accountants advising SME and private company clients, this is a rare opportunity. Defaulting companies can clear backlogs, regain active status, or even exit cleanly from the register — all at a fraction of the normal punitive fees and with immunity from prosecution for the covered defaults.
1. The Three Options Under CCFS-2026
The scheme is not a single track. CCFS-2026 offers three distinct routes depending on whether the client wants to stay active, become dormant, or exit the register entirely.
Route A — File overdue documents at 10% additional fees
This is the headline benefit. For any company that has fallen behind on ROC filings, the scheme reduces the additional fee component of late filing to 10% of what would otherwise be payable under the Companies (Registration Offices and Fees) Rules, 2014. Standard filing fees remain payable at normal rates.
Route B — Apply for dormant status via MSC-1 at 50% of normal fee
Companies that have not carried on significant business for two years or more, and that want to become formally dormant under Section 455 of the Companies Act, 2013, can file Form MSC-1 at half the usual filing fee during the scheme window.
Route C — Apply for strike-off via STK-2 at 25% of normal fee
Companies that want to exit the register entirely (voluntary strike-off under Section 248) can file Form STK-2 at quarter the usual fee during the scheme window.
2. Forms Covered Under Route A
The scheme covers most commonly-defaulted event-based and annual filings. The forms explicitly referenced include:
- MGT-7 / MGT-7A — Annual Return (and the OPC/small company variant)
- AOC-4 / AOC-4 CFS / AOC-4 XBRL — Financial Statement filings (standalone, consolidated, XBRL variants)
- ADT-1 — Auditor appointment intimation
- FC-3 / FC-4 — Annual accounts and returns for foreign companies
- Other event-based filings notified by the MCA from time to time
Important caveat: The relief is on the additional fee (late fee), not the normal filing fee. So a company with an overdue AOC-4 filing still pays the standard filing fee — it just saves 90% of the late penalty component.
3. Who Is Eligible — and Who Is Not
Eligibility is defined by exclusion. The scheme is open to all companies registered under the Companies Act, 2013 (and erstwhile Companies Act, 1956), except the following categories:
- Companies that have already received a final notice for strike-off from the Registrar prior to the scheme's commencement
- Companies that had already applied for dormant status or strike-off before the scheme commenced (they are in process under the existing regime)
- Companies that have already been dissolved
- Companies classified as "vanishing companies" under the MCA's list
A defaulting company that has received only a preliminary notice (not a final strike-off notice) typically remains eligible — CAs should verify the exact status on the MCA portal before advising the client.
4. Immunity From Prosecution
The scheme offers immunity from prosecution for the specific defaults regularised under the scheme. This is a significant benefit: once a filing is made under CCFS-2026, the MCA will not initiate prosecution or adjudication for that particular default.
The immunity does not cover:
- Substantive offences unrelated to filing (e.g., misrepresentation, fraud)
- Defaults outside the covered form list
- Matters already before the NCLT or courts
5. The Sequence CAs Should Follow
For a client with multiple overdue filings, a clean execution sequence matters:
1. Audit the default list. Pull the company's MCA portal status. Identify every overdue form, the fiscal year it relates to, and the current additional fee standing. The savings on Route A scale with how deep the backlog is — a company with 4-5 years of unfiled AOC-4/MGT-7 gets the biggest benefit.
2. Decide the strategic track first. If the company is truly dormant (no operations, no intention to restart), Route B (MSC-1) or Route C (STK-2) is often cheaper overall than clearing every backlog filing under Route A.
3. Verify eligibility before filing. Check that no final strike-off notice has been issued and that the company is not on the vanishing-companies list. Filing under CCFS when ineligible wastes the filing fee and does not provide immunity.
4. Complete KYC and director compliances first. DIR-3 KYC and DIN activation issues can block AOC-4/MGT-7 filings. Resolve these before attempting the scheme filings, otherwise the benefit window may close mid-filing.
5. File in the correct order. For annual returns, the general rule is to file oldest first, in chronological order — MGT-7 for the earliest defaulted year, then AOC-4 for the same year, then proceed forward.
6. Retain the SRN and payment challan for every filing. These are the client's proof that immunity under CCFS-2026 applies — keep them in the compliance file alongside the Board's resolution.
6. What Happens After 15 July 2026
Once the window closes:
- Additional fees revert to normal — which can be substantial. The Companies (Registration Offices and Fees) Rules, 2014 prescribe Rs. 100 per day for many forms, capped at multiples of the normal fee based on the delay.
- Immunity is not available — any prosecution already initiated or subsequently initiated will proceed on its merits.
- The MCA typically follows up schemes like this with enforcement drives — companies that ignored the window are often the first targets of subsequent strike-off or adjudication proceedings.
For companies with genuine intent to remain active and compliant, missing this window is an expensive choice.
7. Where to Verify the Primary Source
The governing document is MCA General Circular No. 01/2026 dated 24 February 2026, available on the MCA website under Notifications & Circulars. The e-form fee calculator on the MCA portal will reflect the CCFS-2026 reduced rates automatically during the scheme window — if it is not reflecting the reduced rate, check that the form, the company class, and the scheme eligibility are all correctly applied.
Summary
CCFS-2026 gives companies with filing backlogs a 12-week window (15 April → 15 July 2026) to regularise their ROC position at a fraction of the normal cost, with immunity from prosecution for covered defaults. CAs have roughly eleven weeks remaining. For any client sitting on an overdue AOC-4 or MGT-7 stack, this is the conversation to have this month — not in July.
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TaxMarg indexes all MCA circulars, Companies Act sections, and associated rules with direct citations. Readers who want to verify the primary text of General Circular No. 01/2026, Section 455, or Section 248 can look them up with section-level citations.