JASMINE KAUR HUDA
Chartered Accountant
Published on: Mar 27, 2026
MCA Launches One-Time Compliance Window: Companies Compliance Facilitation Scheme, 2026 (CCFS-2026)
Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) The Companies Compliance Facilitation Scheme was launched by the Ministry of Corporate Affairs on 24 February 2026 through General Circular No. 01/2026 to provide assistance to companies in clearing long overdue ROC compliance obligations by giving significant reductions in fees and a very limited form of immunity from penalties. This is a unique, one-time opportunity for companies to improve compliance and receive some relief from penalties due to the burden of the significant number of late fees being imposed under ROC regulations.
Scheme Duration
- The scheme is open for 3 months from 15 April 2026 to 15 July 2026.
- All eligible filings must be completed within this window to avail benefits.
Key Benefits of CCFS‑2026
1. Major Relief on Additional Fees
Under the normal regime, delayed ROC filings attract:
- ₹100 per day per form as additional fee with no cap, leading to huge liabilities for multiple years of defaults.
Under CCFS‑2026:
- Companies need to pay the normal statutory filing fee plus only 10 % of the additional fee that would otherwise be due.
- This effectively reduces 90 % of the penalty burden on overdue filings.
Note: The scheme does not waive the normal government filing fees — those remain payable as usual.
2. Forms Covered
The scheme covers a set of “relevant e‑forms” under both the Companies Act, 2013 and the legacy Companies Act, 1956. These include:
- Annual Return forms: MGT‑7, MGT‑7A
- Financial Statement forms: AOC‑4 (and variants such as AOC‑4 CFS, AOC‑4 XBRL)
- Other forms: ADT‑1, FC‑3, FC‑4
- Old Act forms under the 1956 Act, such as Form 20B, 21A, 23AC, 23ACA, Form 66, Form 23B.
These are the primary statutory filings that carry heavy penalties when overdue — and thus are the main focus of the scheme.
Immunity From Penalties
Under CCFS‑2026, companies and their officers may receive immunity from penalty and prosecution:
-
For Annual Return (Section 92) and Financial Statements (Section 137) filings:
- If the pending filings are completed before any adjudication notice is issued, or
- Within 30 days from the issuance of such a notice, then no penalty shall be levied under these sections.
- Immunity is granted provided no prosecution or notice has been initiated before the filing under the Scheme.
However, if an adjudication order has already been passed or the notice period has expired, the Scheme does not absolve the company of existing liabilities — only additional fees for filing under the Scheme are reduced.
Other Strategic Options Under the Scheme
Dormant Company Status
- Inactive companies can choose to apply for dormant status under Section 455 by filing Form MSC‑1.
- Only 50 % of the normal filing fee is payable for this application.
- Dormant companies remain on the register with minimal compliance requirements.
Strike‑Off Option
- Companies wishing to exit can file Form STK‑2 to strike off the name from the register.
- This can be done with only 25 % of the normally applicable filing fee.
Who Cannot Avail the Scheme
The scheme does not apply to:
- Companies already under a final strike‑off notice.
- Companies that have already applied for strike‑off or dormant status before the Scheme’s inception.
- Entities already dissolved pursuant to amalgamation or classified as “vanishing” companies.
Why This Matters
Long-standing ROC filings have become too expensive for most companies due to the introduction of the ₹100/day additional fee structure in 2018; particularly MSMEs, startups and smaller firms will experience high costs. CCFS‑2026 represents a once-in-a-lifetime opportunity for companies to clean up their compliance records and lower their penalty risk, and to either exit their business totally with a significantly reduced cost or continue to operate legally.
Important Takeaway
This 90‑day compliance window is a strategic opportunity for companies that have not filed:
- Annual Returns (MGT‑7 / MGT‑7A)
- Financial Statements (AOC‑4 variants) …to regularise their ROC compliance at a fraction of historical penalty costs, provided they file within the Scheme period.
