CCFS 2026: How to Revive, Regularise, or Close a Defaulting Company

If you own a company that has fallen behind on its ROC filings, the next few weeks matter more than they look. The Companies Compliance Facilitation Scheme, 2026 (CCFS 2026) closes on 15 July 2026, and it is the cheapest opportunity in years to fix, pause, or shut down a defaulting company. Most explainers stop at describing the scheme. The harder question, and the one you are probably actually asking, is what you should do with it: revive the company, clean it up, put it to sleep, or close it for good. This guide walks you through that decision step by step, and then shows you how to act before the deadline.
What Is CCFS 2026?
The MCA introduced CCFS 2026 through General Circular No. 01/2026 dated 24 February 2026, using its powers under Sections 460 and 403 of the Companies Act, 2013. It is the first broad compliance amnesty since the COVID-era schemes of 2020, and it runs for exactly three months, from 15 April 2026 to 15 July 2026.
What makes the scheme valuable is not just the discount on filing your annual returns. It actually opens four different ways out of non-compliance, each at a reduced cost. If you have been treating this as a simple "file or don't file" choice, that is the first thing to unlearn.
The Four Routes at a Glance
Before deciding, here is the whole picture in one place. Read across the row that sounds most like your situation.
| Route | What It Means | Cost Under CCFS 2026 | Best When |
|---|---|---|---|
| Regularise | File all pending returns and stay active | Normal fee + only 10% of the additional late fee (90% waived) | The company is operating or you plan to keep it |
| Go Dormant | Clear the backlog, then pause the entity | Dormant status application at 50% of the normal fee | You want to keep the company for future use |
| Strike Off | Close permanently via Form STK-2 | STK-2 at 25% of the filing fee (75% off) | The company is dead and will not be used again |
| Revive | Restore a struck-off company, then choose a route | NCLT restoration + filings at the concessional fee | The struck-off name still has real value |
Who Can Use CCFS 2026?
The scheme is broad, but not universal. Confirm your company qualifies before you plan anything.
Companies that can use the scheme
- Private Limited Companies with pending annual filings
- One Person Companies (OPCs) with delayed returns
- Unlisted Public Limited Companies with a compliance backlog
- Small companies, and inactive or dormant companies
- In several cases, companies already struck off, by applying for restoration first
Companies that cannot
- Listed companies, which fall under SEBI's framework
- Companies under SFIO investigation or facing serious-fraud proceedings
- Companies that have already received a final strike-off notice from the ROC
- Companies that applied for dormancy or strike-off before the scheme began
- "Vanishing companies" that regulators cannot trace
How to Decide Which Route to Take
This is the core of the decision. Run through these questions in order and stop at the first "yes", that is your route.
- Is the company still operating, or do you want to keep it? Then regularise. File every overdue form and keep the company fully active at 10% of the additional fee.
- Is it inactive, but you want to preserve the name, a licence, or an asset for later? Then take dormant status under Section 455. You keep the entity with minimal ongoing compliance.
- Is it genuinely finished, with no future use and no major assets or liabilities? Then strike it off through Form STK-2.
- Has it already been struck off, but the name still has value? Then revive it through the NCLT under Section 252, and then choose one of the routes above.
- Do you also own an LLP? Plan a separate cleanup, because CCFS 2026 will not cover it.
Where the choice is genuinely difficult, for example when director liability, a funding plan, or a struck-off name with brand value is involved, it is worth getting the position reviewed before filing anything irreversible. Strike-off in particular is permanent and can only be undone by going back to the NCLT.
How to Act Under CCFS 2026: Step by Step
There is no separate opt-in form for CCFS 2026, unlike the earlier CFSS-2020. You simply complete your pending filings on the MCA-21 (V3) portal within the scheme window. Here is the practical sequence once you have chosen your route.
- Confirm your default status. List every overdue filing, such as AOC-4, MGT-7, and ADT-1, for each missed financial year. You must file all pending years, not just the recent ones, to become compliant and qualify for the immunity.
- Pick your route using the decision steps above: regularise, dormant, strike-off, or revive-then-decide.
- Gather the documents for the forms you need to file, including financial statements and any board approvals required for each year.
- Check your digital signature. Make sure the DSC of the signing director is active and valid, as an inactive DSC is a common cause of rejection.
- Complete the relevant forms on the MCA-21 (V3) portal. File the pending annual forms to regularise, the application under Section 455 (Form MSC-1) for dormant status, or Form STK-2 for voluntary strike-off.
- Pay the concessional fee. The portal applies the reduced amounts under the scheme, only 10% of the additional fee to regularise, 50% for dormant status, or 25% for strike-off.
- Submit before 15 July 2026. Aim to finish by around 30 June 2026 so you have buffer time if a form is queried and needs resubmission.
- Keep your acknowledgement. Retain the filing acknowledgements as proof of compliance under the scheme.
The Cost Math: Why the Deadline Is About Money
The clearest way to see why 15 July matters is in rupees. Take a small private limited company that has not filed its AOC-4 or MGT-7 for a few years. Under Section 403, the additional fee is Rs. 100 per day, per form, with no upper limit, so the backlog quietly compounds the longer it sits.
| Aspect | File Under CCFS (before 15 July 2026) | File After the Deadline |
|---|---|---|
| Additional late fee | Only 10% of the accumulated amount | The full amount, at Rs. 100 per day per form |
| Risk of prosecution | Conditional immunity once filings are complete | ROC may begin adjudication or prosecution |
| Director disqualification risk | Reduced | Rising with each additional year |
| Practical outcome | A clean slate at a fraction of the cost | A penalty bill that can run into lakhs |
Common Mistakes to Avoid
- Treating it as file-or-nothing: dormancy and strike-off are part of the same scheme; for a dead company, closing it cleanly is often cheaper than reviving it.
- Filing only recent years: clearing part of the backlog does not make the company compliant or trigger the immunity, all pending years must be filed.
- Rushing to strike off: strike-off is permanent; if the name, GST history, or a licence still has value, dormancy is usually the smarter pause.
- Forgetting the LLP: CCFS 2026 does not cover LLPs, so an LLP backlog needs its own plan.
- Waiting until July: portal congestion near the deadline causes rejected forms and missed benefits.
Key Takeaways
CCFS 2026 is a rare, time-boxed chance to put a defaulting company back in order, on whatever terms make sense for you. To summarise:
- CCFS 2026 runs from 15 April to 15 July 2026 and waives 90% of the additional late fee on overdue ROC filings.
- It opens four routes: regularise (10% of the additional fee), dormant status (50% of the normal fee), strike-off via STK-2 (25% of the fee), or revive a struck-off company through the NCLT and then choose.
- Decide by asking whether you still need the company, then file directly on the MCA-21 (V3) portal, as there is no separate opt-in form.
- It does not cover LLPs, and it applies only to MCA and ROC filings, not income tax or GST.
- After 15 July 2026, the full Rs. 100-per-day penalty returns and the risk of director disqualification and prosecution rises.



