MCA CCFS-2026 Amnesty Scheme: 90% Fee Waiver for Pending ROC Filings (April 15 to July 15)
The Ministry of Corporate Affairs (MCA) has issued General Circular No. 01/2026 dated February 24, 2026, introducing the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). This is a one-time amnesty window that allows defaulting companies to clear their pending statutory filings at drastically reduced costs, with immunity from prosecution in certain cases.
The scheme opens on April 15, 2026 and closes on July 15, 2026. If your company or your client’s company has overdue annual returns, financial statements, or auditor appointments, this is the most cost-effective opportunity to regularise compliance before the ROC begins enforcement action.
What Is the CCFS-2026 Scheme?
CCFS-2026 is a compliance amnesty scheme that offers three distinct benefits:
- 90% waiver on additional (late) filing fees for pending annual filings
- 50% fee reduction for companies applying for dormant status
- 75% fee reduction for companies applying for voluntary strike-off
The scheme also provides immunity from prosecution under Sections 92 (Annual Return) and 137 (Financial Statements) of the Companies Act, 2013, if filings are made before any adjudication notice is issued, or within 30 days of such a notice.
Which Forms Are Covered?
The scheme covers a comprehensive list of e-forms related to annual compliance filings:
| Form | Purpose | Fee Benefit |
|---|---|---|
| MGT-7 / MGT-7A | Annual Return | Pay only 10% additional fee |
| AOC-4 / AOC-4 CFS / AOC-4 XBRL | Financial Statements | Pay only 10% additional fee |
| AOC-4 NBFC (Ind AS) | NBFC Financial Statements | Pay only 10% additional fee |
| ADT-1 | Auditor Appointment | Pay only 10% additional fee |
| FC-3 / FC-4 | Foreign Company Returns | Pay only 10% additional fee |
| Form 20B, 21A, 23AC, 23ACA, 66, 23B | Legacy Forms (pre-2014 Act) | Pay only 10% additional fee |
| MSC-1 | Application for Dormant Status | Pay 50% of normal fee |
| STK-2 | Voluntary Strike-Off | Pay 25% of normal fee |
Who Is Eligible?
All companies registered under the Companies Act, 2013 (or the former Companies Act, 1956) that have pending annual filings can avail of this scheme. This includes:
- Active companies with overdue annual returns or financial statements
- Inactive companies that have not been filing for multiple years
- Companies that want to transition to dormant status
- Companies that wish to voluntarily wind up through strike-off
Who Is Not Eligible?
Companies against which the Registrar of Companies (ROC) has already initiated final strike-off action under Section 248 of the Companies Act, 2013 are excluded from this scheme. If the ROC has issued the final notice for strike-off, the company cannot use CCFS-2026.
Cost Savings: A Practical Example
Consider a private limited company that has not filed its annual return (MGT-7) and financial statements (AOC-4) for the last 3 financial years. Under the normal fee structure, the additional late filing fees would accumulate to approximately Rs 1,80,000 or more (depending on the company type and delay period).
Under CCFS-2026, the same company would pay only 10% of the additional fees, saving approximately Rs 1,62,000. Add the normal filing fees, and the total cost drops significantly compared to filing outside the scheme window.
What Happens After July 15, 2026?
This is critical. The MCA circular explicitly directs Registrars of Companies to initiate necessary enforcement action against companies that fail to regularise their pending filings during the scheme window. This means:
- Full additional fees (100%) will apply for any filings made after July 15
- Prosecution proceedings under Sections 92 and 137 can be initiated
- Director disqualification risk increases for companies with persistent non-compliance
- ROCs may initiate suo motu strike-off proceedings under Section 248
Practical Implications
For CA Professionals
Send advisory circulars to all clients with pending ROC filings immediately. The April 15 opening is less than three weeks away. Start preparing the overdue financial statements and annual returns now so that filings can be made as soon as the portal opens. Prioritize clients with 3+ years of pending filings, as their savings will be the highest.
For Founders and Startups
If you incorporated a company but never commenced operations (or stopped operations), this is your chance to either obtain dormant status at 50% fee or apply for strike-off at 25% fee. Dormant companies that failed to file for years often face DIN deactivation for directors, blocking them from serving on boards of their active ventures. Clear the backlog now.
For MSME Owners
Many MSMEs incorporated as private limited companies but operate more like proprietorships, with compliance filings falling behind. Under CCFS-2026, you can clear all pending filings at 10% of the late fees. This removes the risk of ROC enforcement, director disqualification, and complications during bank loan renewals or government tender applications where compliance certificates are required.
Action Checklist Before April 15
- Audit your MCA compliance status: Check the MCA V3 portal for all pending forms
- List all overdue forms: Identify which financial years have missing AOC-4, MGT-7, and ADT-1 filings
- Prepare financial statements: Get audited accounts ready for all pending years
- Decide the company’s future: Active (file pending returns), Dormant (file MSC-1), or Strike-off (file STK-2)
- Engage your CS or CA: File as early as possible after April 15 to avoid last-minute portal congestion near July 15
Key Dates at a Glance
| Event | Date |
|---|---|
| Circular issued | February 24, 2026 |
| Scheme opens | April 15, 2026 |
| Scheme closes | July 15, 2026 |
| ROC enforcement begins | After July 15, 2026 |
Need help assessing your company’s compliance gaps or preparing filings under CCFS-2026? The regulatory advisory team at A S Banka Advisors Private Limited assists companies with ROC filings, annual compliance, and corporate restructuring. Get expert guidance from our team before the scheme opens on April 15.
Disclaimer: This article is for informational purposes only and does not constitute legal or professional advice. Please consult a qualified Company Secretary or Chartered Accountant for advice specific to your company’s situation. Information is current as of March 27, 2026.