CCFS-2026 Deadline July 15, 2026: The Companies Compliance Facilitation Scheme Closeout Checklist Before the 10 Per Cent Late-Fee Window Shuts
Quick Summary: CCFS-2026 in Five Lines
- What: The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) lets defaulting companies clear pending Registrar of Companies (ROC) filings by paying only 10 per cent of the additional (late) fee, a 90 per cent relief on accumulated penalties.
- Authority: MCA General Circular No. 01/2026 dated 24 February 2026, issued under Sections 460 and 403 of the Companies Act, 2013.
- Window: 15 April 2026 to 15 July 2026. As of 2 June 2026 you have roughly 43 days left. There is no indication of an extension.
- Covered forms: the annual-filing set, mainly MGT-7 / MGT-7A, AOC-4 and its variants, ADT-1, and FC-3 / FC-4 for foreign companies.
- Bonus exits: inactive companies can also use the window to apply for dormant status or strike-off at reduced fees, plus immunity from prosecution for the delayed filing.
What CCFS-2026 Is, and Why the Closing Six Weeks Matter
If you are a CA or a founder sitting on a company with two or three years of unfiled annual returns and financial statements, CCFS-2026 is the cheapest exit you will see for a long time. The Ministry of Corporate Affairs introduced the scheme through General Circular No. 01/2026 dated 24 February 2026, drawing on the powers in Section 460 (condonation of delay) and Section 403 (fee for filing) of the Companies Act, 2013. The scheme opened on 15 April 2026 and shuts on 15 July 2026.
We covered the step-by-step portal mechanics when the window opened in our CCFS-2026 practical filing guide. This advisory is different. With the scheme now past its halfway mark, the job is no longer “understand the scheme.” It is “triage every defaulting company on your roster and decide, for each one, whether to file, to make it dormant, or to strike it off, before the 10 per cent door closes.” That decision is what this piece walks through.
The core benefit is simple arithmetic. Outside the scheme, the additional fee for a late annual filing can run to 12 times the normal fee for filings delayed beyond 12 months, and it compounds across each pending form and each pending year. CCFS-2026 collapses that additional fee to 10 per cent. The normal filing fee is still payable; it is only the penal additional fee that is cut by 90 per cent.
Which Forms Does CCFS-2026 Cover?
The scheme is built around the annual-filing backlog. The commonly used covered forms are set out below.
| Form | Purpose | Who files it |
|---|---|---|
| MGT-7 / MGT-7A | Annual return (MGT-7A is the abridged return for One Person Companies and small companies) | All companies |
| AOC-4 and variants (AOC-4, AOC-4 XBRL, AOC-4 CFS, AOC-4 NBFC) | Filing of financial statements, including consolidated statements and the NBFC and XBRL variants | All companies, as applicable |
| ADT-1 | Intimation of appointment of auditor | Companies that have not recorded auditor appointments |
| FC-3 / FC-4 | Annual accounts and annual return of a foreign company | Foreign companies operating in India |
The practical reading is that CCFS-2026 targets the annual-compliance backlog (return plus accounts plus auditor intimation). Confirm on the MCA portal whether a specific event-based form you need to file is inside the scheme before assuming the 10 per cent fee applies to it.
Who Can Use the Scheme, and Who Is Locked Out
Eligibility is deliberately broad: any company that has fallen behind on the covered filings can generally come clean under CCFS-2026. The exclusions are the cases where the corporate registry has already moved on or where the entity is a problem case.
Excluded, as summarised across professional commentaries on the circular:
- Companies against which the ROC has already issued a final notice of strike-off.
- Companies that have themselves applied for strike-off before the scheme.
- Companies that had applied for dormant status before the scheme.
- Companies amalgamated or dissolved under a scheme of arrangement.
- Vanishing companies as identified by the regulator.
If your client falls into one of these buckets, CCFS-2026 will not rescue the pending filings, and you should plan around the relevant strike-off, revival, or restoration route instead.
The Immunity: What CCFS-2026 Protects You From
The fee relief is the headline, but the immunity is what lets directors sleep. Under the scheme, a company that completes its pending filings within the window gets immunity from prosecution and from penalty proceedings that arise from the delay in filing. Read the boundaries carefully:
- Relief from the additional fee is automatic once you file inside the window at the 10 per cent rate.
- Immunity from penalty for the delay generally applies where the filing is completed before a penalty notice is issued, or within 30 days of receiving such a notice.
- Penalties that have already been finally adjudicated before the scheme are not refunded or wiped out. The immunity is forward-looking on the act of late filing, not a clawback of money already paid under a concluded order.
So the cleanest outcome goes to companies that file proactively now, before any adjudication starts. The longer a defaulting company waits, the higher the chance a penalty notice lands and narrows the immunity.
The Two Exits for Shell and Inactive Companies
CCFS-2026 is not only for companies that intend to keep trading. Many founders carry a dead holding company or a never-launched SPV that simply accrues penalties. The scheme gives two discounted ways to retire such an entity, both worth using before 15 July 2026:
- Dormant status (Form MSC-1): keep the company alive but switch it to dormant under Section 455 of the Companies Act, 2013, at a reduced filing fee under the scheme. Suitable where you want to preserve the name or a future option.
- Strike-off (Form STK-2): remove the company from the register under Section 248 at a reduced filing fee. Suitable where the entity has no assets, no liabilities, and no future use.
Professional commentaries on the circular report the reduced fee as roughly 50 per cent of the normal fee for the dormancy route and 25 per cent for the strike-off route. Treat those percentages as indicative and confirm the exact fee the MCA portal computes for your case before you commit, because the saving still depends on getting the underlying annual filings up to date first where required.
The CCFS-2026 Closeout Checklist (Run This for Every Defaulting Company)
This is the practitioner sequence for the final six weeks. Run it client by client.
- Pull the master data. For each company, list every overdue financial year and every covered form not filed (MGT-7/7A, AOC-4 set, ADT-1, FC-3/FC-4). Check the MCA portal master data and the company’s own records against each other.
- Confirm eligibility. Verify the company is not on the excluded list (final strike-off notice, prior dormant or strike-off application, amalgamation, vanishing-company tag).
- Fix the prerequisites. AOC-4 needs adopted financial statements; MGT-7 needs a completed annual return. Where board or member approvals are missing for past years, hold the meetings and pass the resolutions now so the forms are signable.
- Sequence the filings. File accounts (AOC-4) and the annual return (MGT-7/7A) for the oldest pending year first, then move forward year by year. File ADT-1 for any unrecorded auditor appointment.
- Verify the fee. Before paying, confirm the challan reflects the 10 per cent additional fee. If the portal is charging the full additional fee, stop and recheck that the filing is inside the covered set and the window.
- Decide the endgame for shells. For inactive entities, choose dormant (MSC-1) or strike-off (STK-2) and file within the window to capture the reduced fee.
- Diarise 15 July 2026. Build a buffer. Do not aim to file on the last day; portal load and payment failures spike near scheme deadlines.
- Document the immunity. Keep the SRN, challan, and filing acknowledgements on file so the company can evidence that it filed within the window if any penalty query arises later.
What It Costs to Miss the 15 July 2026 Window
If a defaulting company does not file by 15 July 2026, the additional fee reverts to the normal late-fee structure under Section 403, which for filings delayed beyond 12 months can reach 12 times the normal fee per form, per year. On a company three years behind on both AOC-4 and MGT-7, that is six penal filings stacking up at the full rate. Beyond money, continued default keeps directors exposed to disqualification under Section 164(2) for companies that have not filed financial statements or annual returns for three continuous financial years, and keeps the company exposed to ROC strike-off action. The scheme is, in effect, a one-time amnesty on the fee; the underlying obligation and its consequences do not pause.
Frequently Asked Questions on CCFS-2026
Is CCFS-2026 the same as the old CFSS 2020 scheme?
It serves a similar purpose, a one-time relief on late-filing fees for the annual-compliance backlog, but it is a distinct scheme with its own circular (General Circular No. 01/2026), its own window (15 April to 15 July 2026), and its own 10 per cent fee structure. Do not rely on CFSS 2020 timelines or terms.
Does the scheme waive the normal filing fee too?
No. The relief is on the additional (penal) fee, which drops to 10 per cent. The normal filing fee for each form is still payable.
Can a company file only some pending forms under the scheme?
The benefit applies to the covered forms you actually file within the window. There is no rule forcing an all-or-nothing filing, but partial filing leaves the company exposed on the remaining defaults at the full fee after 15 July, and may keep the three-year disqualification clock running. Clearing everything is the point.
Will CCFS-2026 be extended beyond 15 July 2026?
As of 2 June 2026, the notified end date is 15 July 2026 and there is no announced extension. Plan on the hard date. Treating a possible extension as a given is how backlogs miss amnesty windows.
Our company already paid a penalty under an adjudication order last year. Can we claim it back?
No. Penalties finally adjudicated before the scheme are not refunded. The scheme’s relief is on the late-filing fee and forward immunity for filings made within the window, not a clawback of concluded orders.
The Bottom Line for CAs and Founders
CCFS-2026 is a 90 per cent discount on penal filing fees with a fixed expiry. The work between now and 15 July 2026 is triage and execution: list the defaults, confirm eligibility, fix the approvals, file oldest year first, and retire the dead shells through dormancy or strike-off. Every client you clear now avoids the 12-times penal fee and the Section 164(2) disqualification exposure later. Forty-three days is enough time to clear a normal backlog, and not enough to start on 14 July.
Need a second pair of eyes on a messy ROC backlog before the window shuts? If you are weighing whether to file, make dormant, or strike off a group of companies under CCFS-2026, schedule a strategy session and we will help you build the closeout plan. This article is brought to you by Tax Update India.
Disclaimer: This article is for general information only and does not constitute legal, tax, or professional advice. CCFS-2026 details are based on MCA General Circular No. 01/2026 dated 24 February 2026 and professional commentaries available as on 2 June 2026. Scheme terms, covered forms, and fees should be confirmed against the official MCA circular and the MCA portal for your specific facts before acting. Consult a qualified professional for advice on your situation.
You can reach out to the author on : info@asbanka.com
www.asbanka.com
- CBDT FAQ Deep-Dive Series #7: Section 43B Actual-Payment Deductions and the 43B(h) MSME Disallowance Under the Income-tax Act 2025 – How Section 37 Maps the Transition Before the September 30, 2026 Tax Audit - June 5, 2026
- DIR-3 KYC Due Date June 30, 2026: The New Triennial Director KYC Rule, Who Must File This Year, and the Rs 5,000 DIN Reactivation Penalty - June 5, 2026
- Form 16 for FY 2025-26: The June 15, 2026 Employer Deadline, the Rs 100 Per Day Penalty, and the Pre-Issue TRACES Checklist - June 2, 2026