MCA CCFS 2026: Clear Pending ROC Filings with 90% Fee Waiver

If your company has pending annual returns or financial statement filings on the MCA portal, the next 11 days may be the most consequential compliance deadline of the year. The Ministry of Corporate Affairs launched the Companies Compliance Facilitation Scheme 2026 (CCFS-2026) via MCA General Circular No. 01/2026 dated 24 February 2026 — a limited-window amnesty scheme that lets companies clear years of overdue ROC filings by paying only 10% of the accumulated additional fees. The window closes on 15 July 2026. Miss it, and the penalties revert to full amount — after which the ROC is authorised to initiate strike-off proceedings and director disqualification actions against defaulting companies.

This is not a routine compliance reminder. For thousands of small private limited companies in India, missed MGT-7 (Annual Return) and AOC-4 (Financial Statements) filings have been silently accumulating late fees that can run into lakhs of rupees. CCFS-2026 is the first broad amnesty scheme of this scale in over five years, and your CA needs to be acting on it today.

What Is CCFS-2026 and What Does It Cover?

The Companies Compliance Facilitation Scheme 2026 draws its authority from Section 460 read with Section 403 of the Companies Act, 2013, which empower the Central Government to condone delays in filing and waive accumulated additional fees in the public interest. It was introduced via MCA General Circular No. 01/2026 dated 24 February 2026.

Under the scheme, any company registered under the Companies Act, 2013 (or the erstwhile Companies Act, 1956) can file the following overdue e-forms on the MCA21 portal during the scheme window:

• MGT-7 — Annual Return (for all companies except OPCs and small companies)
• MGT-7A — Annual Return (for One Person Companies and small companies)
• AOC-4 — Financial Statements (and all variants: AOC-4 XBRL, AOC-4 CFS, AOC-4 NBFC, AOC-4 NBFC Ind AS)
• ADT-1 — Intimation of auditor appointment
• FC-3 — Annual accounts of foreign companies
• FC-4 — Annual return of foreign companies

The core relief: Instead of paying normal fees plus 100% of accumulated additional fees, you pay normal fees plus only 10% of the additional fees. The remaining 90% is waived outright.

A Real Numbers Example

Consider a private limited company with paid-up capital of ₹10 lakh that has not filed MGT-7 or AOC-4 for financial years 2021-22, 2022-23, and 2023-24. On the MCA portal, additional fees for each form accumulate at a fixed daily rate beyond the due date. For three years of pending MGT-7 and AOC-4 filings combined, a company of this size could face ₹4–6 lakhs in accumulated additional fees across all overdue forms.

Under CCFS-2026:

• Pay the normal filing fee (approximately ₹300–600 per form)
• Pay only 10% of the accumulated additional fee — say ₹40,000–60,000 instead of ₹4–6 lakhs
• Net saving: ₹3.6 to ₹5.4 lakhs in a single compliance exercise

For a company that has been dormant or has missed filings due to operational disruptions, this is a substantive financial relief that will not come again anytime soon.

Who Is Eligible — and Who Is Not?

The scheme follows a negative-list approach: all companies are eligible by default unless specifically excluded. Five categories cannot avail CCFS-2026:

1. 1Companies that have already received a final notice of strike-off from the ROC under Section 248(1)
2. 2Companies that have already applied for voluntary strike-off under Section 248(2)
3. 3Companies already ordered to be wound up by the NCLT
4. 4Companies under active insolvency resolution under the IBC, 2016
5. 5Companies that have already applied for Dormant Status under Section 455

If your company does not fall into any of these five categories and has overdue ROC filings, it qualifies. Verify your company status with a CIN-based search on the MCA portal before proceeding.

A Note on Director Disqualification

Under Section 164(2) of the Companies Act, 2013, a director stands automatically disqualified for five years if the company fails to file annual returns or financial statements for three consecutive financial years. By regularising pending filings under CCFS-2026 before 15 July 2026, directors of defaulting companies can substantially reduce this exposure.

CCFS-2026 provides compliance facilitation — it does not grant automatic immunity from all legal consequences. If a director has already received a disqualification notice under Section 164(2), consult your CA to understand whether the CCFS filing alone is sufficient or whether additional steps are required.

Before vs Under CCFS-2026: What Changed

The previous comparable scheme — Company Fresh Start Scheme 2020 (CFSS-2020) — was introduced during COVID-19. CCFS-2026 is the first broad compliance relief of this scale since then.

Step-by-Step Action Checklist

Here is exactly what to do before 15 July 2026:

Step 1: Audit the MCA Portal

Log into www.mca.gov.in, search by CIN, and review the company filings tab. Note every overdue e-form, the financial year it relates to, and the approximate additional fee shown on the portal.

Step 2: Gather Financial Statements for Each Overdue Year

For each year of default, assemble:

• Audited Balance Sheet and Profit & Loss account signed by the statutory auditor
• Directors Report (including any MGT-9 annexure if applicable for certain company sizes)
• Auditor Report on financial statements

If audited financials are not available for older years, the statutory auditor must prepare and sign backdated accounts before any portal filing. Begin this immediately — it is not a one-day process.

Step 3: File AOC-4 Before MGT-7 — Always

Annual Return (MGT-7) requires the date of the Annual General Meeting at which accounts were adopted. That date is first recorded in AOC-4. Filing MGT-7 without a corresponding AOC-4 creates data inconsistencies that the portal may reject. Always follow the sequence: AOC-4 first, then MGT-7, for each financial year.

Step 4: File ADT-1 for Any Missed Auditor Appointments

Companies must intimate the ROC within 15 days of appointing or re-appointing a statutory auditor via Form ADT-1. Overdue ADT-1 filings carry their own additional fees and are covered under the scheme. File these alongside the annual return filings.

Step 5: Pay on the MCA21 V3 Portal

The MCA21 portal automatically computes the concessional additional fee under the scheme when you proceed to payment. Pay via net banking, NEFT, or debit/credit card. Download and preserve the SRN (Service Request Number) for each filing as evidence.

Step 6: File Oldest Financial Year First

If multiple years are pending, file in chronological order — oldest year first. This ensures each annual return correctly references the preceding year filed documents and avoids data mismatch errors on the portal.

Options for Inactive or Dormant Companies

If the company is inactive and there are no plans to revive operations, CCFS-2026 provides two exit paths at concessional cost:

Dormant Status (Section 455): Apply via Form MSC-1. Under CCFS-2026, the application fee carries a 50% waiver. A dormant company must file annual Form MSC-3 but is exempt from most operational compliance obligations. This option preserves the company name and registration for future revival.

Voluntary Strike-Off (Section 248(2)): Apply via Form STK-2. Under CCFS-2026, the filing fee is only 25% of the normal amount. This is the permanent closure route — the company is removed from the register entirely. Ensure all assets are distributed and bank accounts are closed before filing.

Both options require the company to first clear outstanding annual filings. Your CA must verify eligibility conditions for each route before proceeding.

Common Mistakes to Avoid

Waiting until July 14 or 15: The MCA portal experiences very heavy traffic near compliance deadlines. DSC signing failures, payment gateway timeouts, and form submission errors are common. File by 10 July at the absolute latest to leave a buffer for technical issues.

Skipping the auditor sign-off: AOC-4 requires auditor-signed financial statements. If a company has not been audited for two or three years, the statutory auditor must prepare those accounts before any portal filing can occur. This is not a one-day process.

Overlooking ADT-1 filings: Many companies file MGT-7 and AOC-4 but overlook the ADT-1 for auditor appointments. Overdue ADT-1 filings carry their own fees and must be filed separately. They are also eligible for the 90% waiver under CCFS-2026.

Assuming CCFS-2026 waives all penalties: The scheme waives the additional fee under Section 403 only. Outstanding adjudication notices under Section 134 (for late signing of accounts) or other proceedings must still be addressed separately through the standard process.

Confusing compliance facilitation with legal immunity: CCFS-2026 does not provide immunity from criminal prosecution under Section 447 or investigations by the Serious Fraud Investigation Office (SFIO). It addresses the administrative late-filing fee — nothing more.

Key Takeaways

• MCA CCFS-2026 lets companies file overdue MGT-7, MGT-7A, AOC-4, ADT-1, FC-3, and FC-4 at normal filing fee plus only 10% of accumulated additional fees — an effective 90% late fee waiver.
• The scheme window runs from 15 April to 15 July 2026 — very few days remain as of today.
• A company with 3 years of pending annual filings could save ₹3–5 lakhs compared to filing at full rates after the scheme closes.
• After 15 July 2026, the ROC will initiate adjudication proceedings, director disqualification actions, and strike-off notices without further warning.
• Always file AOC-4 before MGT-7, file oldest year first, and submit before 10 July to avoid portal congestion.

How corpus Helps

Managing overdue filings across a portfolio of client companies is exactly where corpus pays for itself. Every client financial statement — Balance Sheet, Profit & Loss account, trial balance — is maintained within corpus and available for immediate export. When a deadline like CCFS-2026 arises, your team does not scramble for files or chase clients for Excel data from three years ago.

corpus also maintains a compliance calendar that surfaces overdue ROC filing obligations across your entire client base, so your firm can see at a glance which companies need AOC-4 and MGT-7 filed before 15 July. If you are handling filings for 10 or 15 clients this week, corpus lets you work through them systematically without missing a single entity.

File before 15 July 2026 — because once this window closes, the 90% relief disappears and the ROC starts issuing notices.