MCA's CCFS-2026 Amnesty: Clear Overdue ROC Filings at ~90% Off Before 15 July
The MCA Companies Compliance Facilitation Scheme 2026 (CCFS-2026) lets companies clear pending AOC-4, MGT-7 and other overdue filings by paying only 10% of the additional fee — a roughly 90% waiver — between 15 April and 15 July 2026. Here is who qualifies and how to use the window.
- CCFS-2026, notified via MCA General Circular 01/2026, runs from 15 April 2026 to 15 July 2026 (Vinod Kothari Consultants, 2026).
- Companies pay the normal filing fee plus only 10% of the additional late fee on pending annual filings — an effective ~90% waiver.
- Dormant-status filings (MSC-1) cost 50% of the normal fee and strike-off (STK-2) just 25% during the window.
If your company has skipped a few ROC filings, the MCA has handed you a rare discount. The Companies Compliance Facilitation Scheme 2026 (CCFS-2026), introduced by MCA General Circular 01/2026 dated 24 February 2026, runs from 15 April to 15 July 2026 and lets defaulting companies clear pending forms by paying the normal fee plus only 10% of the additional late fee — an effective ~90% waiver (Vinod Kothari Consultants, 2026).
For a small private limited company or OPC that let AOC-4 and MGT-7 slip during a busy year, the ordinary penalty is ₹100 per day per form with no cap. CCFS-2026 replaces that pileup with a small fraction of the cost. The catch is the window: miss 15 July and the full penalties return.
- CCFS-2026 runs 15 April to 15 July 2026 under MCA General Circular 01/2026.
- Pending annual filings: pay normal fee + only 10% of the additional (late) fee.
- Dormant status (MSC-1): 50% of normal fee. Strike-off (STK-2): 25%.
- No separate immunity form — benefits apply automatically when you file in the window.
What exactly is CCFS-2026?
It is a one-time compliance-relief scheme for companies carrying overdue statutory filings. During the window, you file pending forms by paying the normal fee plus just 10% of the additional fee — a roughly 90% cut in the late-filing penalty (Vinod Kothari Consultants, 2026). Issued under Section 460 read with Section 403 of the Companies Act 2013, it echoes the 2020 Companies Fresh Start Scheme but with a cleaner, form-free process.
Think of it as a reset button. Rather than negotiating penalties after an adjudication notice, you pre-empt the whole thing by filing now at a fraction of the cost. If you are also unsure whether the company should stay active at all, this is the moment to decide — the scheme prices both continuation and exit cheaply.
Not sure what your company even owes? Start by mapping your obligations against a complete business registration and compliance guide, then list every missed form.
Which filings does the scheme cover?
CCFS-2026 covers most annual and event-based e-forms — MGT-7 and MGT-7A (annual return), AOC-4 and its variants (financial statements), ADT-1 (auditor appointment), FC-3 and FC-4 for foreign companies, and legacy Companies Act 1956 forms like 20B, 21A, 23AC and 66 (CS Pratik K Shah, 2026). AGM-related defaults under Section 96 are not covered.
So the scheme fixes filing delays, not the failure to hold a meeting. If you held your AGM late but did file, you are squarely inside the relief. If you never held the AGM, that default sits outside CCFS and needs separate handling.
Do I have to file a separate immunity application?
No. Unlike the 2020 Companies Fresh Start Scheme, there is no separate immunity application — the reduced fee and relief from additional-fee penalty apply automatically when you file the pending forms during the window (Vinod Kothari Consultants, 2026). The circular also warns that once the window closes, Registrars of Companies will act against companies that did not use it.
The practical takeaway: file early in the window. Relief is tied to filing during the scheme period, so leaving it to the last week risks a portal glitch or a document delay costing you the concession entirely.
Why does clearing old filings matter for a small company?
Because default compounds. Late fees run at ₹100 per day per form with no ceiling, and three years of non-filing can disqualify directors under Section 164(2)(a) and expose the company to strike-off under Section 248 (TaxGuru, 2025). A disqualified director cannot be appointed elsewhere either — the damage spreads.
All 38 company e-forms, including AOC-4 and MGT-7, now run on the MCA V3 portal, so file there. If the paperwork feels heavier than the business, hand it off — our company compliance team can reconcile what is pending and file it inside the CCFS window.
Your CCFS-2026 checklist
Step 1: pull the company master data on MCA V3 and list every overdue form. Step 2: prepare financials and the annual return for each missed year. Step 3: file during 15 April to 15 July 2026 to lock the reduced fee. Step 4: if the company is inactive, decide between dormant status (MSC-1, 50%) or strike-off (STK-2, 25%) and use the same window.
Do not treat this as an annual event — it is a one-time reset. Once you are clean, keep future filings on schedule with an ongoing compliance calendar so you never need an amnesty again.
What should you verify before using this Company Law guide?
Before acting on mca's ccfs-2026 amnesty, verify the current rules or platform behavior with the GST Portal. The practical answer depends on your business model, state, turnover, documents, software stack, and whether the decision affects tax, customer data, paid media spend, or a production workflow.
Use this article as a working checklist, then confirm thresholds, registration status, return forms, document rules, and portal notices. In our audits, most expensive mistakes do not come from ignoring the whole process. They come from one stale assumption, one mismatched address, one missing event, or one automation path that nobody tested after launch.
| Checkpoint | Why it matters | Where to confirm |
|---|---|---|
| Current rule or platform status | Limits, forms, policies, and APIs can change after a blog update. | GST Portal |
| Your exact business case | A local shop, freelancer, D2C store, agency, and SaaS team rarely need the same next step. | Documents, invoices, campaign data, analytics setup, or workflow logs |
| Implementation evidence | The safest business decision is backed by proof, not memory or screenshots from an old setup. | Portal acknowledgement, dashboard export, invoice sample, test lead, or error log |
How do we apply this in real business work?
We start with the smallest decision that can be verified. For compliance work, that means matching PAN, address, bank, invoices, and portal status before filing. For websites, marketing, analytics, and automation, it means testing the real user path from first click to final record. The boring checks catch the costly failures.
A useful rule: if a claim changes money, tax, reporting, or customer communication, keep evidence for it. Save the acknowledgement, export the report, test the form, and note the date you verified the source. That gives you a clean trail when a client, officer, platform, or internal team asks why the setup was done that way.
When should you get expert review?
Get expert review when the next action can create tax exposure, lost reporting data, ad waste, broken customer communication, or production downtime. A simple self-check is enough for low-risk learning. A filed return, new registration, tracking migration, paid campaign restructure, or live automation deserves a second set of eyes before it affects customers or records.
How often should this be rechecked?
Recheck the decision whenever your turnover, state, product mix, campaign budget, website stack, analytics property, or workflow ownership changes. Also recheck it after major portal updates, platform policy changes, annual filing deadlines, and vendor migrations. The guide is useful today only if the facts behind it still match your business.
What is the fastest safe way to decide?
Write the decision in one sentence, list the proof needed for that sentence, and verify only those items first. This keeps the work focused. If the proof confirms the decision, proceed. If one item is unclear, pause and resolve that point before changing filings, campaigns, tracking, website code, or automation logic.
What can go wrong if you skip verification?
The usual failure is not dramatic at first. It looks like a rejected application, a wrong tax invoice, a missing conversion, a duplicate lead, a broken report, or a workflow that silently stops. Those small failures become expensive when nobody notices them until month-end reporting, filing day, or a customer escalation.
What evidence should you keep after making the change?
Keep enough evidence to reconstruct the decision later. For a compliance topic, that usually means the application reference number, registration certificate, invoice sample, return acknowledgement, payment challan, notice reply, or source link checked on the day of filing. For a website, campaign, analytics setup, or automation, keep the before-and-after screenshot, test submission, dashboard export, webhook log, and the exact setting that changed.
This matters because most business fixes are revisited months later, when nobody remembers the original reason. A short evidence trail makes audits faster, handovers cleaner, and vendor conversations more precise. It also keeps the advice in this guide tied to your real operating context instead of becoming a generic checklist that gets copied without review.
- Date checked: record when the official source, dashboard, or portal screen was reviewed.
- Business context: note the entity, state, product, campaign, property, or workflow affected.
- Proof of action: save the acknowledgement, report export, test result, or live URL.
- Owner: assign one person to re-check the item when rules, tools, or business volume change.
Which next step should you take after reading this?
Turn the article into one action list. Mark what is already true, what needs proof, and what needs expert review. If you want to go deeper, compare this guide with Pvt Ltd Registration, LLP Registration, and Business Registration. Then update the decision only after the official source and your own records agree.
Frequently asked questions
What is the CCFS-2026 scheme?
The Companies Compliance Facilitation Scheme 2026 is a one-time compliance-relief scheme introduced by MCA General Circular 01/2026 dated 24 February 2026, issued under Section 460 read with Section 403 of the Companies Act 2013. During the window from 15 April to 15 July 2026, defaulting companies can file pending forms by paying the normal fee plus only 10% of the additional (late) fee, a roughly 90% reduction on the penalty.
Which filings does CCFS-2026 cover?
It covers most annual and event-based e-forms — MGT-7/MGT-7A (annual return), AOC-4 and its variants (financial statements), ADT-1 (auditor appointment), FC-3/FC-4 for foreign companies, and legacy Companies Act 1956 forms like 20B, 21A, 23AC and 66. AGM-related defaults under Section 96 are not covered, so the scheme fixes filing delays, not the failure to hold a meeting.
Is there a separate immunity form to file?
No. Unlike the 2020 Companies Fresh Start Scheme, there is no separate immunity application. The reduced fee and relief from the additional-fee penalty apply automatically when you file the pending forms during the window. The circular warns that after the scheme closes, Registrars of Companies will act against companies that did not use it, so acting early in the window is safest.
Why does clearing old filings matter for a small company?
Continued default invites late fees of ₹100 per day per form with no cap, and can trigger director disqualification under Section 164(2)(a) after three years of non-filing, plus possible strike-off under Section 248. CCFS-2026 is a rare chance to reset at roughly 10% of the penalty cost. All 38 company e-forms now run on the MCA V3 portal, so file there.
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