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MCA’s CCFS-2026: A Big Compliance Relief for Companies with Pending Filings

If your company has old MCA filing defaults, this may be the easiest and most cost-effective chance to clean them up.

The Ministry of Corporate Affairs, through General Circular No. 01/2026 dated 24 February 2026, has launched the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). The Scheme opens a limited window for companies to complete pending annual filings, move into dormant status, or apply for strike off at sharply reduced cost.

Why this Scheme matters

  • Delayed filing of annual return and financial statements normally attracts an additional fee of ₹100 per day, with no upper cap.

  • Many companies, especially MSMEs, private companies, OPCs and inactive entities, have been carrying old compliance defaults and large additional fee exposure.

  • CCFS-2026 offers a one-time opportunity to reduce this burden and regularise records on the MCA registry.

Key reliefs under CCFS-2026

Companies can choose any of the following routes during the Scheme period:

  • Complete pending annual filings by paying only 10% of the applicable additional fees

  • Apply for dormant status through e-Form MSC-1 by paying half of the normal filing fee

  • Apply for strike off through e-Form STK-2 by paying only 25% of the applicable filing fee

Effective dates

  • Scheme start date: 15 April 2026

  • Scheme end date: 15 July 2026

    Important forms covered

The Scheme covers several commonly delayed forms, including:

  • MGT-7 / MGT-7A

  • AOC-4

  • AOC-4 CFS

  • AOC-4 NBFC (Ind AS)

  • AOC-4 CFS NBFC (Ind AS)

  • AOC-4 (XBRL)

  • ADT-1

  • FC-3

  • FC-4

It also covers certain legacy forms under the Companies Act, 1956, such as 20B, 21A, 23AC, 23ACA, 23AC-XBRL, 23ACA-XBRL, 66 and 23B.

Who cannot use the Scheme?

The Scheme is not available to:

  • companies against which final notice for strike off under section 248 has already been initiated

  • companies that have already filed for strike off

  • companies that had already applied for dormant status before the Scheme started

  • companies dissolved pursuant to amalgamation

  • vanishing companies

    Is there immunity from penalty?

Yes, but only in specified cases.

For defaults under section 92 and section 137:

  • no penalty will be leviable if filing is made:

    • before issuance of notice by the adjudicating officer, or

    • within 30 days of such notice

But note:

  • if filing is done after the 30-day period, or

  • if an adjudication order has already been passed,
    then the penalty liability does not automatically disappear merely because the filing is made under the Scheme.

    For forms like ADT-1, FC-3, FC-4 and certain legacy forms:

  • immunity from prospective penal action is available if:

    • the form is filed under the Scheme, and

    • no prosecution or adjudication proceedings had already begun before such filing.

      What companies should do now

  • review all pending MCA annual filings

  • calculate the additional fee exposure

  • decide whether the company should:

    • continue and regularise,

    • become dormant, or

    • proceed for strike off

  • act well before 15 July 2026, since the circular clearly states that RoCs will take action against companies that do not avail the Scheme and remain in default.

    Closing thought

CCFS-2026 is more than a fee relief scheme — it is a practical compliance reset. For companies sitting on old defaults, this is a valuable window to clean up records, reduce exposure, and avoid future enforcement action.

Companies-Compliance-Facilitation-Scheme-2026-February252026

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