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Companies Compliance Facilitation Scheme (CCFS) 2026: MCA’s One-Time Window for Regularising Pending ROC Filings

CA Adityavikram Banka

The Ministry of Corporate Affairs (MCA) has announced the Companies Compliance Facilitation Scheme (CCFS) 2026, a one-time amnesty window under Sections 403 and 460 of the Companies Act, 2013. The scheme will be operational from 15th April 2026 to 15th July 2026, offering companies a three-month window to regularise overdue filings with the Registrar of Companies (ROC) at significantly reduced penalties.

For CA professionals, founders, startups, and MSME business owners, this scheme represents a major opportunity to clean up compliance records before MCA tightens enforcement. Here is everything you need to know.

What is CCFS 2026?

CCFS 2026 is a limited-period compliance relief scheme that allows defaulting companies to file pending annual returns and financial statements with the ROC at drastically reduced additional fees. The scheme also provides concessional routes for companies seeking to apply for dormant status or voluntary strike-off from the register.

Under normal circumstances, non-filing of annual returns and financial statements attracts an additional fee of Rs. 100 per day of delay, along with a fixed penalty of Rs. 50,000 — costs that can escalate into lakhs for multi-year defaults. CCFS 2026 offers up to 90% waiver on these accumulated additional fees.

Key Features of the Scheme

1. Reduced Fees for Pending Annual Returns & Financial Statements

Companies filing overdue Form MGT-7 (Annual Returns) or Form AOC-4 (Financial Statements) during the CCFS window need to pay only the normal filing fee plus 10% of the accrued additional fees. This translates to a 90% effective waiver on penalty amounts — a substantial saving for companies with multi-year defaults.

2. Concessional Dormant Company Application

Companies that have not conducted any business or financial transactions can apply for dormant status using e-Form MSC-1 at 50% of the normal filing fee. Dormant status allows a company to remain on the register without active compliance obligations, making it ideal for shell companies or businesses on temporary hold.

3. Discounted Voluntary Strike-Off

Defunct companies that wish to be removed from the register can file e-Form STK-2 at just 25% of the normal cost. This is particularly relevant for founders and promoters who incorporated companies that never commenced business or that have been inactive for years. Voluntary strike-off during the CCFS window removes the company cleanly from the register and protects directors from future liability.

4. Immunity from Prosecution

One of the most significant benefits is the immunity provision. Companies that file their pending Annual Returns and Financial Statements before any adjudication notice is issued will be immune from penalties and prosecution for the period of default. This protection extends to other forms like ADT-1, FC-3, and Form 23AC where no prior prosecution exists.

Who is Eligible?

Eligible entities include:

  • Companies with pending Annual Returns (Form MGT-7)
  • Companies with overdue Financial Statements (Form AOC-4)
  • Inactive companies seeking dormant status
  • Defunct companies applying for voluntary strike-off

Who cannot apply:

  • Companies with final strike-off notices already issued by ROC
  • Companies that previously applied for dormancy or strike-off
  • Dissolved companies or “vanishing companies” (untraceable entities)

Fee Structure Summary

Filing Type Cost Under CCFS 2026
Pending Annual Returns / Financial Statements Normal fee + 10% of additional fees
Dormant Company Application (MSC-1) 50% of normal filing fee
Strike-Off Application (STK-2) 25% of normal filing fee

Why This Matters for Different Stakeholders

CA Professionals: This is a golden opportunity to proactively reach out to clients with pending ROC filings. Many companies — especially private limited companies incorporated by first-time founders — accumulate years of non-compliance. CCFS 2026 gives you a concrete deadline and financial incentive to present to clients for regularisation.

Founders & Startups: If you incorporated a company that never took off, or if your startup has been informal about ROC compliance, this is the time to act. The cost of regularising now is a fraction of what it will be after 15th July 2026. More importantly, having clean ROC records is essential for future fundraising, bank account operations, and regulatory approvals.

MSME Business Owners: Many MSMEs operate as private limited companies but treat compliance as an afterthought. CCFS 2026 gives you a low-cost path to bring your company records up to date, which is increasingly important as banks, lenders, and government schemes (like MSME registration under Udyam) cross-verify MCA records.

Important Caveats

  1. Director Disqualification: CCFS 2026 does NOT automatically reverse director disqualification under Section 164(2). Directors disqualified for non-filing will need separate remediation
  2. LLP Applicability: Whether LLPs are covered depends on the final MCA notification. Keep an eye on the official gazette for clarification
  3. Strict Deadline: Missing the 15th July 2026 deadline means losing all CCFS benefits permanently. There is no guarantee of an extension
  4. The Scheme is Optional: Companies are not required to use CCFS, but given the massive fee savings, there is little reason not to

Action Plan

  1. Audit Your MCA Filing Status: Check the MCA portal (mca.gov.in) for your company’s filing history and identify all overdue forms
  2. Prepare Financial Statements: If your books of accounts are not up to date, begin preparation immediately — you need completed financials before you can file AOC-4
  3. Engage Your CA: Work with your chartered accountant to prioritise filings and take advantage of the CCFS fee structure
  4. Decide: Regularise, Go Dormant, or Strike Off: For inactive companies, evaluate whether it makes more sense to bring filings current, apply for dormancy, or go for voluntary strike-off
  5. File Before the Deadline: Set a firm internal deadline of 30th June 2026 to allow buffer time before the 15th July cutoff

Conclusion

The Companies Compliance Facilitation Scheme, 2026 is one of the most significant compliance relief measures from MCA in recent years. With up to 90% waiver on accumulated penalties and concessional routes for dormancy and strike-off, it provides a practical and cost-effective path for thousands of non-compliant companies to regularise their records.

Whether you are a CA advising clients, a founder with a dormant company, or an MSME owner who has fallen behind on filings — the message is clear: act before 15th July 2026.

Stay tuned to taxupdate.in for step-by-step filing guides and practical tips for making the most of CCFS 2026.

Disclaimer: This article is for informational purposes only and does not constitute legal or professional advice. Readers are advised to consult qualified professionals for specific guidance.

CA Adityavikram Banka
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