CCFS 2026: The MCA Amnesty Scheme Has Closed. Here Is What to Do Now
The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) let defaulting companies file overdue annual returns and financial statements by paying only 10% of the additional fees. The window closed on 15 September 2026. If your company missed it, we clear the backlog at normal rates and help you limit penalties.
What it is
CCFS 2026 was a one-time relief scheme from the Ministry of Corporate Affairs (MCA). Companies that had not filed annual returns or financial statements could file them by paying the normal fee plus just 10% of the additional fee.
General Circular No. 01/2026 (24 February 2026) announced it, running from 15 April to 15 July 2026. General Circular No. 03/2026 (8 July 2026) extended it to 31 August 2026, and General Circular No. 04/2026 (31 August 2026) gave a final extension to 15 September 2026.
The scheme is over. An overdue form filed today attracts the full additional fee, and the circular tells each Registrar of Companies (ROC) to act against companies that did not use it.
Who it applies to
Companies behind on annual filings
The scheme covered pending MGT-7, MGT-7A, AOC-4 (all versions), ADT-1, FC-3 and FC-4, plus the matching 1956 Act forms.
Inactive companies
Under the scheme, dormant status in MSC-1 cost half the normal fee and closure in STK-2 cost 25% of the fee. Both routes remain open at full fee.
Not LLPs
LLPs were never covered. Also left out: companies facing a final strike-off notice, those that had already applied to close or go dormant, companies dissolved by amalgamation, and vanishing companies.
Why it matters
You pay the late fee in full
AOC-4 and MGT-7 now carry ₹100 per day of delay. File one 300 days late and the additional fee is ₹30,000. Under CCFS it would have been ₹3,000.
Expect ROC action
ROCs are directed to act against companies that skipped the scheme: penalty notices, strike-off, director disqualification.
Protect your directors
Under Section 164(2)(a), if a company skips financial statements or annual returns for three continuous financial years, its directors cannot be reappointed there or appointed to any other company for five years.
Documents required
Financial records
- Audited financial statements for every pending year
- Auditor’s report and board’s report
- Bank statements, if accounts are still to be prepared
Company records
- Shareholder and director list for each year
- AGM dates or minutes, where held
- Auditor appointment details for ADT-1
For filing
- Valid DSC of a director
- Active DIN with DIR-3 KYC up to date
- Any ROC or adjudication notice received
CCFS 2026 at a glance
| Item | During CCFS-2026 | From 16 September 2026 |
|---|---|---|
| AOC-4, MGT-7, MGT-7A | Normal fee + 10% of additional fee | Normal fee + ₹100 per day of delay |
| ADT-1, FC-3, FC-4 | Normal fee + 10% of additional fee | Normal fee + full additional fee |
| Dormant status (MSC-1) | 50% of normal fee | Full fee |
| Strike-off (STK-2) | 25% of the fee | Full fee of ₹10,000 |
| Penalty under Sections 92 and 137 | Immunity if filed before an adjudication notice, or within 30 days of one | Penalty can be levied |
For ADT-1, FC-3, FC-4 and the older forms, immunity applied only if no prosecution had been filed and no show cause notice issued. Here is the catch: the fee cut is gone, but the default keeps running. Each day you wait adds ₹100 per pending annual form.
How it works
Check your MCA status and pending forms
We pull your master data and filing history from the MCA V3 portal and list each pending form, year by year.
Decide: revive, go dormant or close
If the business runs, we bring your annual ROC filings up to date. If it has stopped, we compare dormant status under Section 455 with closing the company through STK-2. Take a Faridabad software start-up that went quiet in 2023 and never filed again: closing it may cost less than keeping it alive.
Prepare accounts and file oldest year first
Your statutory auditor audits the accounts and signs the report. We coordinate that, then file ADT-1, AOC-4 and MGT-7 or MGT-7A year by year. In practice, filing in date order keeps the previous-year figures in each AOC-4 consistent.
Reply to any ROC notice
If an adjudication notice arrives, we draft the reply and show the adjudicating officer that the default has been made good.
Timelines
Scheme window
15 April 2026 to 15 September 2026, after two extensions.
Regular annual deadlines
AOC-4 is due within 30 days of the AGM and MGT-7 within 60 days of it. The AGM must be held by 30 September.
Adjudication notice reply
Under CCFS, filing within 30 days of a notice gave immunity. Now, reply within the time stated in the notice.
What happens if you missed CCFS
Full additional fee
₹100 per day on AOC-4 and MGT-7, with no upper cap. Event-based forms cost 2× to 12× the normal fee depending on the delay.
Penalty under Sections 92 and 137
₹10,000 plus ₹100 per day of continuing default, up to ₹2 lakh for the company and ₹50,000 for each officer in default. Small companies and OPCs pay half under Section 446B.
Strike-off and disqualification
The ROC can remove a company that has done no business for two financial years under Section 248(1). Directors face five-year disqualification under Section 164(2).
Frequently asked questions
Is CCFS 2026 still open?
No. CCFS 2026 closed on 15 September 2026. It ran from 15 April 2026 and was extended twice, first to 31 August 2026 by General Circular No. 03/2026 and then to 15 September 2026 by General Circular No. 04/2026. Forms filed now attract the normal additional fee. Do not wait for another scheme: every extra day adds ₹100 per pending form.
What relief did CCFS-2026 give?
It cut the late fee to 10% of the additional fee on overdue annual forms. This covered MGT-7, MGT-7A, AOC-4, ADT-1, FC-3 and FC-4. Dormant status in MSC-1 cost half the normal fee, and STK-2 for closure cost 25% of the fee. Many companies also got immunity from penalty under Sections 92 and 137.
Were LLPs covered by CCFS-2026?
No. The scheme covered companies only, and LLP forms such as Form 8 and Form 11 were not in the list. LLPs pay additional fees as multiples of the normal fee under the LLP rules in force since 1 April 2022. If your LLP is behind on filings, we work out the exact fee and file the pending forms in order.
How much will I pay now for a late AOC-4 or MGT-7?
You pay the normal filing fee plus ₹100 for every day of delay, for each form. The normal fee is ₹200 to ₹600 depending on the company’s nominal share capital. So an AOC-4 filed 200 days late carries ₹20,000 in additional fee alone. We work out the total for every pending year before we start.
Can the ROC still penalise me if I file now?
Yes. Without the scheme there is no automatic immunity, so the adjudicating officer can levy a penalty under Section 92(5) or 137(3). The penalty is ₹10,000 plus ₹100 per day, up to ₹2 lakh for the company. Filing before a notice arrives still helps, because the daily default stops and you show good faith. We handle the reply if a notice comes.
My company has stopped business. Should I file everything or close it?
Decide whether you will ever restart. If you may, dormant status under Section 455 keeps it alive with lighter filings. If not, STK-2 under Section 248(2) closes it, at a fee of ₹10,000. Either way, pending financial statements and annual returns up to the end of the year in which business stopped must usually be filed first. We help you pick the cheaper path.
Is there any way to reduce the late fee now?
Not on the additional fee itself, which the MCA V3 portal calculates automatically. What you can control is the penalty. Small companies and One Person Companies pay half the penalty under Section 446B, and filing before an adjudication notice usually counts in your favour. We also check that every year shown as pending really is pending before you pay anything.
How long does it take to clear a backlog?
Most of the time goes into preparing and auditing accounts for the old years. Once audited accounts are ready, filing takes a few days per year on the MCA V3 portal. A Faridabad trading company with three pending years and tidy bank statements and bills can often be brought up to date in a few weeks.
What it costs
Our fee plus the government fee that applies to your case, quoted before you commit. Tell us the situation and we will price it exactly.
Government fees now: normal fee of ₹200 to ₹600 per form based on nominal share capital, plus ₹100 per day of delay on AOC-4, MGT-7 and MGT-7A. STK-2 costs ₹10,000.
Ready to begin?
Missed CCFS 2026? Send us your CIN and we will list every pending form and its cost within one working day.