CCFS 2026 ROC Filing: Clear Pending Returns at 90% Discount (April 15–July 15)

⟳ Updated April 2026

CCFS 2026 ROC Filing · MCA Late Fee Waiver 2026 · General Circular No. 01/2026

CCFS 2026 ROC Filing:
Clear Pending MGT-7 & AOC-4 at 90% Discount Before July 15

The MCA late fee waiver 2026 scheme is live from April 15. Defaulting companies have exactly 91 days to file pending returns at a fraction of the accumulated penalty — before ROC crackdown begins.

🏛 MCA · Companies Act 2013 ⏱ 8 min read 🚨 Deadline: 15 July 2026
0%

Waiver on
Additional Fees

0 Days

Scheme Window
Apr 15 – Jul 15

₹0

Penalty Per Day
Without Scheme

0 Options

File / Dormant
/ Strike-Off

CCFS 2026 ROC filing — company directors reviewing MCA compliance documents
⚡ Key Takeaways — CCFS 2026 ROC Filing Scheme
  • 90% waiver on accumulated additional fees — companies pay only 10% of the ₹100/day penalty that has accrued since 1 July 2018. Verify at mca.gov.in.
  • Scheme window is strictly April 15 – July 15, 2026 — MCA has signalled no extension. Late action means full penalty resumes from July 16.
  • Three exit paths available: file pending MGT-7/AOC-4 (10% fees), apply for dormant status — MSC-1 (50% fees), or close the company via STK-2 (25% fees).
  • Immunity from prosecution under Sections 92 and 137 of the Companies Act, 2013 — if filed before any adjudication notice, or within 30 days of one. File at MCA-21 portal.
  • Post-scheme ROC enforcement: the circular explicitly states that Registrars will initiate strict action — including director disqualification — against companies that do not use this window.

The CCFS 2026 ROC filing window opened on April 15, 2026. For every company carrying overdue annual returns or financial statements with the Registrar of Companies, this is the single most cost-effective compliance opportunity since 2018. The MCA late fee waiver 2026 — formally titled the Companies Compliance Facilitation Scheme, 2026 — was introduced via General Circular No. 01/2026 dated 24 February 2026, exercising powers under Sections 460 and 403 of the Companies Act, 2013.

Since 1 July 2018, the Companies Act has levied ₹100 per day in additional fees for every delayed annual return and financial statement, with no upper cap. For a company that has missed filings over three or four years, that figure compounds rapidly into amounts that make voluntary compliance financially impossible. CCFS 2026 resets that equation — and the July 15 deadline is firm.

1 What Is CCFS 2026? Understanding the MCA Late Fee Waiver Scheme

CCFS stands for Companies Compliance Facilitation Scheme. The 2026 version is a one-time amnesty introduced by the Ministry of Corporate Affairs to reduce the backlog of non-compliant companies in the MCA-21 registry. It is not the first scheme of this nature — the MCA introduced similar windows in 2010 and 2020 — but the 2026 iteration carries sharper post-scheme enforcement language than its predecessors.

The scheme operates on a straightforward logic: companies that have been unable to file due to accumulated penalties can now regularise at 10% of the total late fees otherwise owed. The base statutory filing fee remains payable in full. Only the additional fee component — the ₹100/day penalty — receives the 90% discount. The MCA late fee waiver 2026 covers both the Companies Act, 2013 and legacy forms under the Companies Act, 1956.

📋
Option A — File Pending Returns
Pay only 10% of accumulated additional fees on MGT-7, AOC-4, ADT-1, FC-3, FC-4 and legacy 1956 Act forms.
💤
Option B — Dormant Status
Apply for dormancy under Section 455 via e-Form MSC-1 at 50% of the normal filing fee. Reduces future compliance burden.
🔒
Option C — Strike Off
Close the company permanently via e-Form STK-2 at just 25% of normal fees. Begin immediately — process takes 2–4 months.

2 CCFS 2026 ROC Filing: Which Forms Are Covered?

The CCFS 2026 ROC filing concession applies across a defined list of statutory forms. Annual returns and financial statements carry the highest default volume and receive the primary 90% fee reduction. The following forms are eligible under the scheme:

Form Purpose Act Fee Relief
MGT-7 / MGT-7A Annual Return Companies Act, 2013 10% of additional fees
AOC-4 / AOC-4 XBRL Financial Statements Companies Act, 2013 10% of additional fees
ADT-1 Auditor Appointment Companies Act, 2013 10% of additional fees
FC-3 / FC-4 Foreign Company Filings Companies Act, 2013 10% of additional fees
20B, 21A, 23AC, 23ACA Annual Return / Balance Sheet Companies Act, 1956 10% of additional fees
MSC-1 Application for Dormant Status Companies Act, 2013 50% of normal fee
STK-2 Voluntary Strike-Off Companies Act, 2013 25% of normal fee
MCA-21 portal for CCFS 2026 ROC filing — company secretary filing MGT-7 and AOC-4

3 The Fee Savings: How Much Does CCFS 2026 Actually Save?

The financial case for using CCFS 2026 is straightforward. Under normal provisions, a company with a single form overdue by three years (approximately 1,095 days) would owe ₹1,09,500 in additional fees — on that one form alone. Under the MCA late fee waiver 2026, that liability reduces to ₹10,950. A company with multiple overdue forms over four or more years can routinely see savings in excess of ₹5–10 lakh.

The example below illustrates fee savings relative to the standard ₹100/day accumulation for a representative small company:

Normal additional fees (3 yrs, 2 forms)₹2,19,000
Fees payable under CCFS 2026₹21,900
Normal additional fees (5 yrs, 3 forms)₹5,47,500
Fees payable under CCFS 2026₹54,750

Savings note: The base statutory filing fee (not the additional penalty) is payable in full under CCFS 2026. The 90% discount applies exclusively to the accumulated ₹100/day additional fee component. Verify your exact fee calculation at efiling.mca.gov.in before filing.

4 Who Qualifies for the CCFS 2026 ROC Filing Scheme?

All companies registered under the Companies Act, 2013 that have overdue annual returns or financial statements are eligible. This includes private limited companies, One Person Companies (OPCs), producer companies, and MSME-registered entities. Foreign companies with overdue FC-3 or FC-4 filings are also covered.

However, four categories are explicitly excluded from the CCFS 2026 ROC filing concession:

Final Strike-Off Notice Issued
Companies against which the Registrar has already issued a final notice under Section 248 cannot use this scheme.
Already Applied for Strike-Off or Dormancy
Companies that filed STK-2 or MSC-1 applications before April 15, 2026 are excluded.
Vanishing Companies
Entities that regulators cannot locate — untraceable directors and non-operational registered addresses — are not eligible.
Dissolved via Amalgamation
Companies already dissolved through a court-approved scheme of merger or amalgamation cannot avail the scheme.

5 Immunity from Prosecution Under CCFS 2026

One of the most consequential features of the MCA late fee waiver 2026 is the prosecution immunity it provides under Sections 92 and 137 of the Companies Act, 2013. Section 92 governs annual returns; Section 137 governs financial statements. Both carry significant penalty and prosecution exposure for company directors and officers.

The immunity works as follows:

1
File before any adjudication notice
Full immunity — no penalty shall be levied under Sections 92 or 137. All proceedings concluded.
2
File within 30 days of an adjudication notice
Still eligible for immunity — provided the filing and fee payment occur within 30 days from the date of notice.
3
30-day window expired or order already passed
Filing under the scheme does not eliminate existing penalty liability. The CCFS fee discount still applies to additional fees, but prosecution exposure remains.

⚠️ Important: Immunity under CCFS 2026 covers only the filing-related defaults under Sections 92 and 137. It does not extend to other violations of the Companies Act, 2013 or any other statute. Directors facing disqualification under Section 164(2) should note that CCFS 2026 does not automatically reverse existing disqualification orders.

Is Your Company’s ROC Filing Status Clean?

Validraft’s compliance team identifies your pending MGT-7 / AOC-4 obligations, calculates your exact CCFS 2026 fee savings, and files before the July 15 deadline.

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

The CCFS 2026 ROC filing process runs entirely through the MCA-21 V3 portal. Filing between April 15 and July 15, 2026 automatically triggers the reduced fee calculation. There is no separate CCFS application form — the scheme operates through the standard form filing mechanism with the discount applied at the payment stage.

1
Check Master Data on MCA-21
Log in at mca.gov.in and review your company’s filing status. Note every overdue form and the date of default.
2
Prepare Audited Financials and Board Approvals
All backlog financial statements must be audited and board-approved before filing. Conduct the required board meetings and get statutory auditor sign-off.
3
Renew DSCs for All Signing Directors
Verify that Digital Signature Certificates for all directors are active and MCA-registered. Expired DSCs will prevent form submission.
4
Upload and Submit Forms on MCA-21 V3
File MGT-7/AOC-4 (and any other overdue forms) during the scheme window. The portal auto-calculates the 10% reduced additional fee at the payment stage.
5
Retain SRN Acknowledgements as Proof
Save the Service Request Number (SRN) and payment receipt for every form filed. These are documentary proof of compliance under the scheme.

🚨 Timing alert: MCA portal congestion routinely spikes in the final two weeks of such schemes. Do not wait until July. Companies pursuing the strike-off route (STK-2) should file immediately after April 15 — the process takes 2–4 months to complete and final gazette notification must occur before the scheme closes.

7 What Happens After July 15, 2026? Post-Scheme ROC Action

The MCA General Circular No. 01/2026 contains explicit post-scheme enforcement language. Once CCFS 2026 closes, Registrars of Companies are directed to initiate action against all companies that remain in default and did not avail the scheme. This is not a routine circular note — it signals a coordinated enforcement push.

ROC enforcement action after CCFS 2026 deadline — companies that miss the July 15 window face penalties

The consequences for companies that miss the CCFS 2026 ROC filing window and continue defaulting are material:

🚫
Director Disqualification
Directors of defaulting companies face disqualification under Section 164(2) — preventing appointment in any other company for a significant period.
⚖️
Prosecution Under Companies Act
Section 92 and 137 defaults carry prosecution risk for company officers. Filing-related immunity under CCFS 2026 will no longer be available.
🗑️
Forced Strike-Off
The Registrar can initiate compulsory strike-off, complicating recovery of assets and settlement of any outstanding liabilities.

8 CCFS 2026 vs. Normal ROC Compliance: Should You File Now or Wait?

For any company currently in default, the answer is unambiguous — file during the CCFS 2026 window. The 90% reduction in accumulated penalties is not replicated under normal MCA filing provisions, and there is no legislative basis to expect another such scheme to follow immediately. The ₹100/day additional fee resumes in full from July 16, 2026, continuing to compound without limit.

The table below compares the financial and legal position for a company that acts during CCFS 2026 versus one that misses the window and files in October 2026:

Factor File Under CCFS 2026 (Before Jul 15) File After CCFS 2026 (Oct 2026)
Additional Fees 10% of accumulated total 100% of accumulated total + 92 more days
Prosecution Immunity Available under Sections 92 & 137 Not available — full exposure resumes
Strike-Off Fee 25% of normal STK-2 fee 100% of normal STK-2 fee
Dormancy Fee 50% of normal MSC-1 fee 100% of normal MSC-1 fee
ROC Enforcement Risk Eliminated on filing Active — Registrar action expected
Director Disqualification Risk Cleared on regularisation Elevated — continued default after notice period

File Your Pending ROC Returns Before July 15

Validraft handles CCFS 2026 ROC filing end-to-end — from compliance audit to MCA-21 submission and SRN tracking. Flat-fee, deadline-guaranteed.

Start Your CCFS 2026 Filing → Company Closure Services

9 Frequently Asked Questions — CCFS 2026 ROC Filing

What exactly is CCFS 2026 and who issued it? +
CCFS 2026 — the Companies Compliance Facilitation Scheme, 2026 — is a one-time amnesty introduced by the Ministry of Corporate Affairs via General Circular No. 01/2026 dated 24 February 2026. It allows defaulting companies to file pending ROC returns at 10% of accumulated additional fees. The MCA late fee waiver 2026 is active from April 15 to July 15, 2026.
Does CCFS 2026 ROC filing cover all overdue years at once?+
Yes. All pending annual returns and financial statements — regardless of how many years of default — can be filed under CCFS 2026 during the scheme window. The 10% additional fee calculation applies to the total accumulated penalty across all overdue periods. There is no year-wise cap on eligibility.
Is the MCA late fee waiver 2026 mandatory or optional?+
CCFS 2026 is optional — companies are not compelled to use it. However, given that the MCA has explicitly signalled post-scheme enforcement action, companies currently in default should treat it as operationally urgent. The alternative is full penalty resumption from July 16, 2026, with no further concession window committed by the MCA.
Can an LLP file under the CCFS 2026 scheme?+
General Circular No. 01/2026 is issued under the Companies Act, 2013. It covers companies — Private Limited, OPC, public companies, and foreign companies — but LLPs are regulated separately under the Limited Liability Partnership Act, 2008. LLP eligibility under CCFS 2026 is not confirmed in the circular. LLPs should check mca.gov.in for any parallel LLP settlement scheme notification.
What happens to directors if a company misses the CCFS 2026 deadline?+
The CCFS 2026 circular explicitly states that after July 15, 2026, Registrars will initiate action against defaulting companies. For directors, continued non-compliance risks disqualification under Section 164(2) of the Companies Act, 2013 — which prevents the director from being appointed or continuing in any company. Prosecution under Sections 92 and 137 also becomes active with no immunity window available.
Does CCFS 2026 remove a director’s existing disqualification under Section 164(2)?+
No. Filing under CCFS 2026 regularises the company’s compliance status and provides immunity from further filing-related penalties under Sections 92 and 137. It does not automatically reverse existing disqualification orders already passed under Section 164(2). Directors in that position should seek separate legal advice on disqualification removal proceedings.

10 Conclusion: Act on CCFS 2026 ROC Filing Before the Window Closes

CCFS 2026 ROC filing is not a procedural option to be considered later — it is an active, time-bound relief that expires at midnight on July 15, 2026. Every day of delay narrows the preparation window and increases the risk of MCA portal congestion in the final days. The MCA late fee waiver 2026 eliminates 90% of what can be — for companies with several years of overdue returns — a financially crippling accumulated penalty.

The three pathways available under CCFS 2026 — regularise, go dormant, or close — cover every operational scenario a defaulting company might face. Private limited companies, OPCs, MSMEs, and producer companies that have struggled with compliance costs since 2018 now have a structured, affordable route out. Choosing not to act is, in practice, a decision to face full penalties and active ROC enforcement from July 16.

Validraft’s compliance team is equipped to conduct a complete MCA-21 filing audit, calculate your exact savings under the CCFS 2026 scheme, prepare all pending financial statements and annual returns, and file well ahead of the deadline. If your company has outstanding CCFS 2026 ROC filing obligations, the time to act on the MCA late fee waiver 2026 is now.

Validraft Legal Team

Legal Drafting & Compliance · validraft.in · Article based on MCA General Circular No. 01/2026 dated 24 February 2026 and verified scheme provisions. Last reviewed: April 2026.

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