What is CCFS-2026?

The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) is a temporary compliance window introduced by the Ministry of Corporate Affairs (MCA) through General Circular No. 01/2026 dated February 24, 2026. It is issued under Section 460 read with Section 403 of the Companies Act, 2013.

The scheme allows defaulting companies to regularise long-pending statutory filings with the Registrar of Companies (ROC) at dramatically reduced additional fees. It also enables inactive or defunct companies to opt for dormancy or strike-off at heavily discounted rates.

Key Numbers at a Glance

Why Did MCA Launch This Scheme?

Under current rules, companies that delay annual filings face an additional fee of Rs. 100 per day, with no upper limit, from July 1, 2018 onwards. For companies defaulting over several years, the accumulated late fee can run into lakhs of rupees - making compliance practically unaffordable.

MCA received representations from companies, particularly MSMEs and small businesses, about the financial difficulty in clearing these arrears. CCFS-2026 directly responds by temporarily overriding the standard fee structure.

POLICY SHIFT: From 'Settlement' to 'Facilitation'

Unlike earlier Company Law Settlement Schemes (CLSS) focused on settling past defaults, CCFS-2026 marks a move towards a compliance-facilitation framework - focused on proactive governance, accurate corporate registry data, and long-term regulatory discipline. MCA has indicated this is a one-time opportunity and should not be expected to recur.

Three Pathways Under CCFS-2026

Option 1 - Clear Pending Annual Filings

Companies can complete all pending annual filings (financial statements and annual returns) by paying only 10% of the total additional fees otherwise applicable, plus the standard normal filing fee.

Option 2 - Obtain Dormant Company Status

If your company has had no significant business activity for at least the last two financial years, you can apply for dormant status under Section 455 by filing e-Form MSC-1 at just 50% of the normal filing fee.

Option 3 - Voluntary Strike-Off (Closure)

Companies wishing to wind down can apply for removal via e-Form STK-2 by paying only 25% of the applicable filing fee - bringing the cost down from Rs. 10,000 to just Rs. 2,500.

Fee Summary Table

Forms Covered Under CCFS-2026

The scheme covers the following key overdue ROC e-forms:

NOTE ON CSR-2:

For FY 2023-24 and earlier, Form CSR-2 was filed separately. Under MCA V3, CSR-2 details are now integrated into AOC-4. If filing pending AOC-4 forms for earlier years under this scheme, CSR-2 can be included in AOC-4 itself - no separate fee is applicable for CSR-2.

Eligibility - Who Can Use CCFS-2026?

The scheme is open to all companies registered under the Companies Act, 2013, except those in the exclusion list below. Note: LLPs are not covered.

Companies Excluded from CCFS-2026

• Companies against which a final notice for strike-off under Section 248(1) has already been initiated by the Registrar
• Companies that have already filed an application (STK-2) for voluntary strike-off under Section 248(2)
• Companies that have already applied for dormant status under Section 455 before the scheme commenced
• Companies dissolved pursuant to a scheme of amalgamation without winding up
• Companies where the 30-day period after a notice of adjudication under Section 454(3) has already elapsed
• Companies against which an adjudication order imposing penalties has already been passed

Immunity Provisions

A critical question for many companies is whether filing under CCFS-2026 protects them from further penalty action.

For Core Annual Filing Forms (AOC-4, MGT-7, etc.)

Filing before a notice of adjudication is issued, or within 30 days of receiving such a notice, provides full immunity from prospective penal action. However, if an adjudication order has already been passed, those penalties remain payable - the scheme waives the additional filing fee, not penalties already imposed.

For Legacy Forms (ADT-1, FC-3, FC-4, Form 23AC, etc.)

Immunity from prospective penal action is granted provided no prosecution has been filed and no show cause notice for adjudication has been issued before filing under the scheme.

IMPORTANT: AGM Non-Compliance Not Covered

Non-conduct of the Annual General Meeting (AGM) under Section 96 is a separate compoundable offence not covered by CCFS-2026. Companies must file an application before the NCLT to compound such defaults separately

Director Disqualification

If directors have been disqualified under Section 164(2) due to non-filing for 3+ consecutive years, filing under CCFS-2026 does NOT automatically remove that disqualification. This requires a distinct legal remedy such as applying to the NCLT under Section 167(2).

Unlike CFSS-2020, there is no requirement to file a separate immunity certificate form. Immunity is automatic upon timely filing within the scheme window.

Step-by-Step: How to File Under CCFS-2026

1. Audit all pending filings - Log in to the MCA21 portal and check your company's filing history. List all overdue forms across financial years. It is common to discover older missed filings during this review.
2. Gather financial records - Collect board-approved financial statements, auditor's reports, and annual return data for each pending financial year. Ensure DIR-3 KYC for all directors is current.
3. Prepare all forms - Use the MCA V3 portal to prepare the relevant e-forms (AOC-4, MGT-7/7A, etc.) for each year. Professional assistance from a CS or CA is strongly recommended to avoid rejections.
4. Calculate fees and pay - The MCA portal will compute the reduced additional fee (10% of normal additional fee) automatically. Pay the applicable normal filing fee plus the reduced additional fee via the portal.
5. File well before the deadline - The portal sees heavy traffic near deadlines, forms can be rejected and need resubmission, and corrections take time. Filing in April–May 2026 is strongly advisable.
6. Decide on dormancy or closure if applicable - If inactive for 2+ years, consider filing MSC-1 for dormancy or STK-2 for strike-off at the heavily discounted scheme rates.

CCFS-2026 vs Earlier Schemes

Who Should Act Immediately?

This scheme is especially relevant for:

• MSMEs and small companies that missed filings due to cash flow challenges
• Startups and OPCs with compliance backlogs from early growth years
• Dormant businesses that continued to exist legally but stopped operating
• Companies with disqualified directors who need to regularise filings regardless
• Companies facing strike-off notices who can still file before the process is finalised
• Holding/subsidiary companies with missed group-level compliance filings

Final Word: Don't Wait

The MCA has been clear - CCFS-2026 is a one-time opportunity and another similar scheme should not be expected. Once the window closes on July 15, 2026, the standard Rs. 100/day additional fee regime resumes in full, along with adjudication proceedings and potential director disqualification for continued defaults.

The financial savings under this scheme are substantial - a company with 5 years of missed filings could save lakhs in late fees. The time to act is now, and the earlier you start, the fewer complications you encounter.

Ready to clear your compliance backlog?

Don't log into MCA and figure it out alone. Let Targolegal's CA/CS team audit your pending filings, calculate your exact savings under CCFS-2026, and build your filing plan — before July 15, 2026.

It's free. It takes 2 minutes. And it could save your company lakhs.

👉 Book your free compliance consultation →