Companies Compliance Facilitation Scheme, 2026 (CCFS‑2026)

The Companies Compliance Facilitation Scheme, 2026 (CCFS‑2026), is a one‑time relief window notified by MCA (General Circular 01/2026 dated 24‑02‑2026) to let defaulting companies regularize pending ROC filings or exit the register at steeply reduced fees and with conditional immunity from penalties.

1. Overview and objective

CCFS‑2026 runs under sections 403 and 460 of the Companies Act, 2013, and targets delays in filing key annual forms like annual returns and financial statements.

The main objectives are to

(a) clear the backlog of overdue filings,

(b) reduce the additional fee burden,

(c) clean up MCA 21 data, and

(d) give inactive companies a cheaper route to become dormant or get struck off.

2. Scheme period and scope

1. Scheme validity: CCFS‑2026 is open from 15 April 2026 to 15 July 2026; only filings made within this 3‑month window enjoy the reduced fee and immunity benefits.

2. Coverage: It applies to “relevant e‑forms” that relate mainly to annual filing compliances under both the Companies Act, 2013, and the legacy Companies Act, 1956.

   
   

Key forms covered

Under the Companies Act, 2013:

• MGT‑7 / MGT‑7A – Annual return

• AOC‑4, AOC‑4 CFS, AOC‑4 (XBRL) – Financial statements and consolidated financial statements

• AOC‑4 NBFC (Ind AS), AOC‑4 CFS NBFC (Ind AS) – NBFC financial statements

• ADT‑1 – Appointment of auditor

• FC‑3, FC‑4 – Annual filings of foreign companies

Under the Companies Act, 1956 (backlog filings):

• Form 20B, 21A—Annual returns

• Form 23AC, 23ACA, including XBRL variants—Balance sheet and P&L

• Form 66—Compliance certificate

• Form 23B—Information by auditor to ROC

Status‑change web‑forms enabled through scheme:

• MSC‑1 – Application for “Dormant Company” status under section 455

• STK‑2 – Application for striking off the company’s name

Note: Forms like INC‑20A, DPT‑3, etc., are explicitly outside the scheme and continue under the normal regime.

3. Eligibility and exclusions

Eligible entities

• All companies registered under the Companies Act (including private, public, OPCs, small companies, and NBFCs) with pending filings in the specified forms are generally eligible.

• Foreign companies with filing obligations through FC‑3/FC‑4 are also within the ambit.

  
  

Not eligible / excluded

The scheme does not apply to the following categories:

• Companies against which a final notice for striking off has already been issued under section 248 (or section 560 of the 1956 Act).

• Companies that have themselves already filed for voluntary strike‑off before the scheme.

• Companies that applied for dormant status under section 455 before 15 April 2026.

• Amalgamated or dissolved entities and “vanishing companies."

• Companies are already struck off; they would first need restoration through NCLT to be able to file.

  
  

Furthermore, CCFS‑2026 does not cure substantive non‑filing defaults outside the covered e‑forms, such as failure to hold an AGM, which must be handled separately via compounding/adjudication.

4. Fee relief and options under CCFS‑2026

The scheme offers three broad options depending on the company’s stage and intent:

4.1 Option 1 – Clear pending annual filings

• Pay the normal filing fee plus only 10% of the additional fee that would otherwise have been payable (instead of 100% of the additional fee at ₹100 per day with no upper cap).

• This relief applies to overdue annual returns and financial statement filings (MGT‑7/7A, AOC‑4 series, and other listed annual forms).

  
  

In effect, companies receive a 90% waiver on additional fees for the specified pending forms filed between 15 April and 15 July 2026.

4.2 Option 2 – Apply for Dormant Status

• File web form MSC‑1 during the scheme period.

• Pay only 50% of the normal filing fee for MSC‑1.

Benefit: The company remains legally in existence but with significantly reduced ongoing compliance, which suits long‑term inactive entities.

4.3 Option 3 – Strike off (exit route)

• File web‑form STK‑2 for striking off the company’s name.

• Pay 25% of the STK‑2 filing fee, i.e. ₹2,500 instead of ₹10,000.

• Company should be compliant up to the date of cessation or as per strike‑off rules; scheme reduces cost of closure but does not waive basic eligibility requirements for strike off.

5. Immunity and legal protection

CCFS‑2026 provides conditional immunity from certain penalty proceedings, but it is not a blanket amnesty for all company‑law violations.

5.1 Immunity for sections 92 and 137

For Annual Return (section 92) and Financial Statements (section 137):

• If the relevant forms are filed under the scheme (within 15 April–15 July 2026) before an adjudication notice is issued, no penalty will be levied for delay under these sections.

• If adjudication notice has already been issued, immunity is available where filings are completed within 30 days of issuance of such notice, subject to the scheme conditions.

In both cases, companies still pay the reduced additional fee (10%), but escape separate adjudication penalties for past delay under sections 92(5) and 137(3).

5.2 Immunity for other covered e‑forms

• For other specified e‑forms (ADT‑1, FC‑3/FC‑4, legacy 1956‑Act annual forms, etc.):

• Immunity from prospective penal action is granted if:

• The forms are filed under CCFS‑2026; and

• No prosecution has been launched, and no adjudication proceeding (show-cause notice) has been initiated for that specific default prior to filing.

If prosecution or adjudication has already commenced, companies may still use CCFS‑2026 to complete filings with reduced additional fees, but those ongoing proceedings are not automatically dropped and must be dealt with as per law.

5.3 What is not covered by immunity

• Defaults like non‑conduct of AGM, misstatements, or other substantive violations are not condoned by this scheme; they may require compounding or separate adjudication.

• Corrections/re‑filings (e.g., changing AGM date, revising related‑party figures) are also outside scope; the scheme is strictly for pending statutory filings, not for rectifying already‑filed forms.

No separate “immunity application” is required; immunity flows automatically once the relevant forms are successfully filed with reduced fees within the scheme window.

6. Post‑scheme consequences for non‑compliant companies

If a company does not utilise CCFS‑2026 and continues in default after 15 July 2026, the ROC is directed to proceed with strict enforcement:

• Regular additional fees at ₹100 per day without upper limit under section 403 resume for late filings of sections 92 and 137 forms.

• Adjudication under section 454 may impose monetary penalties on the company and each officer in default as per sections 92(5) and 137(3) (up to ₹2,00,000 for the company and ₹50,000 per officer in many cases).

• Suo motu strike‑off actions under section 248 can be initiated against long‑defaulting companies.

• Directors risk disqualification under section 164(2)(a) for three consecutive years’ non‑filing of financial statements or annual returns.

Steps to be taken:

• Identify all pending years and forms (MGT‑7/7A, AOC‑4 series, ADT‑1, FC‑3/4, legacy 20B/21A/23AC/23ACA/66/23B).

• Decide strategy: regularise and continue business (Option 1), shift to dormant if business is on hold (Option 2), or close through strike‑off (Option 3).

• Sequence: prioritise years where adjudication notices are likely or already issued so that filings are completed within 30 days of such notices to lock in immunity.

• Coordinate with auditors on UDIN for older audits; UDIN has to be generated as per ICAI norms on current date even for back‑year filings and is outside the scope of CCFS‑2026 itself.