CCFS-2026 Practical Filing Guide: Step-by-Step MCA V3 Portal Process for the April 15 to July 15 Amnesty Window
Key Takeaways
- The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) opened on April 15, 2026 and closes on July 15, 2026. Source: MCA General Circular No. 01/2026 dated February 24, 2026.
- Defaulting companies pay only 10% of accumulated additional fees on late filings of MGT-7, MGT-7A, AOC-4, ADT-1, FC-3, FC-4 and specified legacy forms.
- Two additional exits: file MSC-1 (dormant status) at 50% of normal fee, or STK-2 (voluntary strike-off) at 25% of normal fee.
- Filing is done exclusively through the MCA-21 V3 portal. The V2 portal is disabled.
- All forms must be filed oldest year first, and DSCs of all signing directors must be valid. Delay to July 15 risks portal congestion and missed immunity.
- Post July 15, 2026: full additional fees (Rs 100 per day) resume, ROC enforcement including adjudication and strike-off action begins.
What Is CCFS-2026 and Why Now?
The Ministry of Corporate Affairs issued General Circular No. 01/2026 dated February 24, 2026 launching the Companies Compliance Facilitation Scheme, 2026. It is a one-time amnesty window for companies that have accumulated pending annual returns and other filings under the Companies Act, 2013 and the Companies Act, 1956. The window runs from April 15, 2026 to July 15, 2026.
The scheme has one simple design goal: get the register of companies clean before the next enforcement cycle. MCA has signalled that post-scheme, strike-off and prosecution action under Sections 92 and 137 of the Companies Act, 2013 will accelerate. CCFS-2026 is the last safe exit.
This guide is a practical, step-by-step filing walkthrough. We covered the policy overview in our earlier post CCFS-2026 MCA Amnesty Scheme Opens April 15 with 90% Fee Waiver. This post focuses on what a CA or founder actually does in the MCA-21 V3 portal between April 15 and July 15.
Three Pathways Under CCFS-2026: Pick Before You File
| Option | When to Use | Fee Under CCFS-2026 | Key Form(s) |
|---|---|---|---|
| Option A: Regularise pending filings | Company is active and operational; management wants to continue business | Normal filing fee plus only 10% of additional fees | MGT-7/7A, AOC-4 (and variants), ADT-1, FC-3, FC-4, Form 20B, 23AC/ACA, Form 66 |
| Option B: Convert to Dormant | Company has no operations, but promoters want to preserve the shell | 50% of normal MSC-1 fee | e-Form MSC-1 |
| Option C: Voluntary Strike-Off | Company is non-operational and promoters want permanent closure | 25% of normal STK-2 fee | e-Form STK-2 |
Forms Covered Under Option A
- Companies Act, 2013 forms: MGT-7 (Annual Return, most companies), MGT-7A (Annual Return, Small Companies and OPCs), AOC-4 (Financial Statements, all variants including XBRL, NBFC, CFS), ADT-1 (Auditor Appointment), FC-3 and FC-4 (Foreign Company filings)
- Companies Act, 1956 legacy forms: Form 20B, Form 21A, Form 23AC and 23ACA, Form 66, Form 23B
Who Is Excluded?
- Companies with a final strike-off notice already issued by ROC
- Companies that have already filed for strike-off or dormant status before the scheme inception
- Dissolved companies
- So-called “Vanishing Companies” on MCA watch lists
- Companies under specific prosecution already finalised with penalty adjudication order
Fee Calculator: A Three-Year Default Example
The math is where CCFS-2026 gets dramatic. Consider a small private limited company that missed MGT-7, AOC-4, and ADT-1 for FY 2022-23, FY 2023-24, and FY 2024-25.
| Year | Days Late (approx) | Normal Additional Fee (Rs 100/day) | CCFS-2026 Fee (10%) |
|---|---|---|---|
| FY 2022-23 | 1,095 days | Rs 1,09,500 | Rs 10,950 |
| FY 2023-24 | 730 days | Rs 73,000 | Rs 7,300 |
| FY 2024-25 | 365 days | Rs 36,500 | Rs 3,650 |
| Total | Rs 2,19,000 | Rs 21,900 |
The 10% CCFS-2026 fee saves Rs 1,97,100. The normal filing fee (not the additional fee) is still payable in full, and differs based on authorised share capital under the Companies (Registration Offices and Fees) Rules, 2014.
Step-by-Step Filing Guide: MCA-21 V3 Portal
All annual filing forms (MGT-7, MGT-7A, AOC-4, ADT-1) migrated to the MCA-21 V3 portal in July 2025. The V2 portal is disabled. Below is the exact workflow.
Step 1: Login and Map the Defaults
- Go to www.mca.gov.in and log in to the V3 portal using the company’s business user ID.
- Open the company’s Master Data tab. Note the date of incorporation, last AOC-4 and MGT-7 filed, and CIN status (active/dormant/strike-off initiated).
- Prepare a filing matrix: one row per form per financial year. List AOC-4, MGT-7, ADT-1 for each pending year. Include FC-3 and FC-4 if the company is a foreign company.
- Order the matrix oldest year first. Chronological filing is mandatory; MGT-7 for FY 2024-25 cannot be accepted if FY 2023-24 is unfiled.
Step 2: Prepare the Documents
- Audited financial statements and Board’s Report for every pending year (AOC-4)
- Annual Return in MGT-7 or MGT-7A format with shareholding details as on 31 March of each pending year
- Board resolutions for auditor appointment (ADT-1), approval of financials, and approval of annual return
- Auditor’s report with CARO annexure where applicable
- Shareholders’ list, director list, and shareholding pattern as of each closing date
- Latest statutory registers: Register of Members, Register of Directors, Register of Charges
- Valid Digital Signatures for all signing directors and the practising CA or CS
Step 3: Verify DSC Validity Before You Start
A single expired DSC can freeze your entire filing cycle. Before filing any form:
- Check each signing director’s DSC expiry date
- Confirm the DSC is registered with MCA V3 against the correct DIN
- If expired, obtain renewal from any certifying authority (eMudhra, Sify, NSDL etc.) and re-register before filing
- Ensure the CA or CS countersigning has a valid DSC registered in V3
Step 4: File the Oldest Year First
Filing order matters. For each pending year:
- File ADT-1 if auditor was appointed/reappointed in that year and ADT-1 is pending
- File AOC-4 with the audited financials. The system will auto-calculate the normal fee. CCFS-2026 logic at the portal will then apply the 10% additional fee concession
- File MGT-7 or MGT-7A with shareholding as on 31 March of that year
- Confirm SRN generated for each filing and download the receipt
- Move to the next year
Step 5: Pay the Concessional Fee
- Payment can be made via net banking, debit card, credit card, or NEFT/RTGS through the V3 payment gateway
- The 10% CCFS-2026 concession will appear as a discount line on the fee challan
- Retain the Service Request Number (SRN), filing receipt, and bank transaction ID
Step 6: Track SRN and Final Approval
- Most CCFS-2026 filings are on straight through processing (STP). Status typically moves from “Pending for Work” to “Approved” within a few working days
- Non-STP filings (for example, certain XBRL AOC-4 filings) may go to ROC for manual scrutiny. Track the SRN on the V3 dashboard
- Respond to any resubmission request within the deadline specified on the portal
Immunity From Prosecution: What You Get and What You Don’t
CCFS-2026 grants immunity from prosecution under Sections 92 (Annual Return) and 137 (Financial Statements) of the Companies Act, 2013 if the filing is made before an adjudicating officer issues a notice, or within 30 days of such notice.
| Situation | Fee Benefit (10%) | Prosecution Immunity |
|---|---|---|
| No notice served, company files voluntarily | Yes | Yes (full immunity) |
| Adjudicating officer notice served; company files within 30 days | Yes | Yes |
| Notice served; more than 30 days elapsed | Yes | No (prosecution continues) |
| Penalty adjudication order already passed | Yes | No |
The key takeaway: even if immunity is lost, the fee concession still applies. But immunity is the real reason to move fast.
Common Mistakes That Will Cost You the Scheme Benefit
- Waiting until early July. Portal congestion in the last two weeks causes SRN delays. File by mid-June for safety.
- Filing the latest year first. The V3 portal will reject MGT-7 for FY 2024-25 if FY 2023-24 MGT-7 is still pending. Oldest first.
- Inadequate documentation. Missing board resolutions or unsigned financials are the top cause of rejection. Use the document checklist before initiating.
- Expired DSCs. A resident director abroad with an expired DSC has stalled many CCFS filings. Renew before April 30.
- Confusion over variant of AOC-4. XBRL applicability, NBFC variant, CFS applicability must each be assessed. The wrong variant leads to rejection.
- Treating shell companies as eligible. Companies with final strike-off notice or already in STK proceedings are excluded.
- Forgetting ADT-1 trail. ADT-1 for every auditor appointment year must be filed before corresponding AOC-4 can be processed.
Pre-April 15 Preparation Checklist
| Task | Owner | Status |
|---|---|---|
| Map all pending forms by financial year | CS or CA | |
| Verify MCA-21 V3 login credentials | Company | |
| Download last 5 years of Master Data and SRN history | CS or CA | |
| Confirm DSC validity for all signing directors | Directors | |
| Audit pending financial statements for each year | Statutory Auditor | |
| Draft board resolutions for each pending year | CS | |
| Prepare shareholding pattern as on each 31 March | CS or CA | |
| Evaluate Option A vs B vs C for the company | Board and Promoters | |
| Estimate total fees payable under CCFS-2026 | CS or CA | |
| Block calendar time for filing in May or early June | Company |
Frequently Asked Questions
Q1. What is the last date to file under CCFS-2026?
July 15, 2026. The scheme is not expected to be extended. File well before that date to avoid portal congestion and to preserve prosecution immunity.
Q2. Can I file only some pending forms and skip others?
You can, but any unfilled pending form continues to attract full additional fees (Rs 100 per day) from July 16, 2026. Annual filings must be done in chronological order; you cannot skip a year in the middle.
Q3. Does CCFS-2026 cover DPT-3, BEN-2, DIR-3 KYC, or CHG-1?
No. CCFS-2026 is restricted to the forms specified in the circular: annual filings (MGT-7/7A, AOC-4 and variants, ADT-1) and foreign company filings (FC-3, FC-4), plus specified 1956 Act legacy forms. Other forms continue at normal fees.
Q4. Our company has been non-operational for five years. Is Option B (MSC-1) or Option C (STK-2) better?
Option B (dormant at 50% MSC-1 fee) preserves the corporate shell, which is useful if promoters plan to revive the company or hold a PAN with carried-forward losses. Option C (strike-off at 25% STK-2 fee) is permanent exit. Before choosing, file all pending annual returns up to the dormant or strike-off date. Evaluate tax and bank account implications with your CA.
Q5. What happens if I miss July 15, 2026?
Full additional fee (Rs 100 per day per form) resumes. ROC is empowered to issue adjudicating officer notices under Section 454 and strike-off notices under Section 248. MCA has indicated that post-scheme enforcement will be aggressive.
Q6. Can LLPs use CCFS-2026?
No. CCFS-2026 applies to companies registered under the Companies Act, 2013 or 1956. A separate LLP amnesty scheme was announced earlier in 2025 and has already closed. Check with your CS if any LLP-specific relief is in force.
Q7. Is immunity automatic or do I need to apply for it?
Immunity flows automatically if you file the pending form before an adjudicating officer notice is issued, or within 30 days of such notice. No separate immunity application is needed. Retain the SRN receipt as proof.
Q8. Our auditor refuses to sign historical financials because management representations are weak. What do we do?
This is a governance issue, not a scheme issue. The auditor may qualify the report or decline to sign. You cannot file AOC-4 without signed financials. Work with the board to reconstruct records, obtain management representations, and, if needed, appoint a new auditor under Section 140. The amnesty will not wait for internal cleanup. Start early.
Disclaimer
This article is for general information only and does not constitute legal, tax, or compliance advice. Companies should confirm applicability, fees, and procedural steps on the MCA-21 V3 portal and with their practising CA or CS. Always refer to the official text of MCA General Circular No. 01/2026 dated February 24, 2026 and related notifications before acting.
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