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

Nebin Binoy
Nebin Binoy
12 min read 85.3K views
Reviewed by Industry Experts & Startup Specialists.
Last Updated: 

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.

CCFS 2026 is a one-time MCA amnesty open from 15 April to 15 July 2026. It lets a defaulting company regularise overdue filings by paying just 10% of the additional late fee (a 90% waiver), take dormant status at 50% of the normal fee, or strike off through Form STK-2 at 25% of the filing fee. A company already struck off can be revived through the NCLT and then filed. After 15 July 2026, the full Rs. 100-per-day penalty returns with no upper limit.

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.

Comparing your four options under CCFS 2026
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
Directors tend to treat this as a binary: file everything, or do nothing and hope. But dormancy and strike-off are part of the very same scheme. For a company that has genuinely stopped trading, closing it cleanly now is often cheaper than reviving it and carrying it forward. Choose based on whether you actually need the company, not on which option feels easiest today.

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
CCFS 2026 applies to companies only. The circular defines a "company" under Section 2(20) of the Companies Act, 2013, which excludes LLPs. If you also run an LLP with overdue filings, its cleanup needs a separate plan.

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.

  1. 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.
  2. 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.
  3. Is it genuinely finished, with no future use and no major assets or liabilities? Then strike it off through Form STK-2.
  4. 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.
  5. 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.

  1. 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.
  2. Pick your route using the decision steps above: regularise, dormant, strike-off, or revive-then-decide.
  3. Gather the documents for the forms you need to file, including financial statements and any board approvals required for each year.
  4. 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.
  5. 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.
  6. 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.
  7. 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.
  8. 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.

Filing under CCFS 2026 versus waiting until after the deadline
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
Past amnesty windows follow a predictable pattern: a rush of filings in the final fortnight, a congested MCA-21 (V3) portal, rejected forms, and people who waited losing the very benefit they were chasing. Finishing by around 30 June 2026 leaves room to fix any DSC or resubmission issues without panic.

Common Mistakes to Avoid

  1. 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.
  2. 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.
  3. 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.
  4. Forgetting the LLP: CCFS 2026 does not cover LLPs, so an LLP backlog needs its own plan.
  5. 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.

Frequently Asked Questions

What is CCFS 2026?
CCFS 2026, the Companies Compliance Facilitation Scheme, 2026, is a one-time relief window introduced by the Ministry of Corporate Affairs through General Circular No. 01/2026 dated 24 February 2026. It lets defaulting companies clear overdue ROC filings by paying only 10% of the additional late fees, a 90% waiver, and also opens discounted routes to dormancy and voluntary strike-off. It is the first broad MCA amnesty since the COVID-era schemes of 2020 and is open from 15 April 2026 to 15 July 2026.
What is the last date for CCFS 2026, and will it be extended?
The last date is 15 July 2026. No extension has been announced, and once the window closes, Registrars are directed to act against companies still in default. Because the MCA-21 (V3) portal tends to get congested in the final fortnight, it is sensible to treat 30 June 2026 as your practical deadline to allow buffer time for resubmissions.
How do I decide whether to revive, regularise, take dormant status, or strike off?
Work through it in order: if the company is operating or you intend to keep it, regularise; if it is inactive but you want to preserve the name or an asset, take dormant status; if it is genuinely finished with no future use, strike it off; and if it has already been struck off but the name still has value, revive it first and then choose one of the other routes. The deciding factor is whether you still need the company.
Is it cheaper to strike off a company or regularise it under CCFS 2026?
It depends on whether you still need the company. For a genuinely dead company with no assets or future use, striking off via Form STK-2 at 25% of the filing fee is usually cheaper than reviving and regularising years of backlog. If the company is active or you plan to keep it, regularising under the 90% fee waiver is the better choice.
How do I file under CCFS 2026?
There is no separate opt-in form, unlike the earlier CFSS-2020. You complete your pending filings directly on the MCA-21 (V3) portal within the scheme window and pay the concessional fees. In short: confirm your default status and pick a route, gather the documents, complete the relevant forms (such as AOC-4, MGT-7, and ADT-1, or STK-2 for strike-off), ensure your digital signature (DSC) is active, pay the reduced fee, and submit before 15 July 2026.
Which forms can I file under CCFS 2026?
The scheme covers commonly pending ROC forms, most importantly AOC-4 (financial statements), MGT-7 or MGT-7A (annual return), and ADT-1 (auditor appointment), among other routine filings. For voluntary closure you file STK-2, and for dormant status you file the application under Section 455 (Form MSC-1). File all pending years, not just the most recent ones.
How much can I save under CCFS 2026?
The scheme waives 90% of the additional late fee, so you pay only 10% of that amount when you regularise. Dormant status is available at 50% of the normal application fee, and voluntary strike-off via STK-2 at 25% of the filing fee. Normal statutory fees are separate from the additional-fee waiver.
Can I revive a company that has already been struck off?
In many cases, yes. You can apply to the National Company Law Tribunal (NCLT) for restoration under Section 252 of the Companies Act, 2013, and once the name is restored, file the pending documents under CCFS 2026 at the concessional fees. Whether it is worth doing depends on whether the struck-off name still carries value, such as a brand, contracts, or GST history.
Does CCFS 2026 cover LLPs?
No. The scheme applies only to companies, as the circular defines a "company" under Section 2(20) of the Companies Act, 2013, which excludes LLPs. An LLP backlog needs a separate strategy.
Will filing under CCFS 2026 stop director disqualification?
Completing your pending filings significantly reduces the risk of disqualification under Section 164(2), which can otherwise disqualify a director across all of their companies for a continuous three-year default. However, the scheme does not automatically reverse a disqualification order that has already been passed.
What happens if I miss the 15 July 2026 deadline?
The full penalty framework returns. Under Section 403, delayed annual filings attract an additional fee of Rs. 100 per day, per form, with no upper limit, which can grow into lakhs for a multi-year backlog, and the ROC may begin adjudication or prosecution against companies still in default.
Can a company that has already received a strike-off notice use CCFS 2026?
Generally, a company that has received a final strike-off notice from the ROC cannot avail the scheme. Conditional immunity from prosecution applies where filings are completed before such a notice is issued, which is why it is important to assess your status and act early in the window.
Should I choose dormant status or strike off the company?
Choose dormant status (under Section 455) if the company is inactive now but you genuinely intend to revive it later, or it holds a name, licence, or asset worth preserving. Choose strike-off only if the company is truly finished with no future use. Many founders rush to strike off and later regret losing a name or GST history they could have kept cheaply through dormancy.
Do I still need to file Income Tax Returns and cancel GST after striking off under CCFS?
Yes. CCFS 2026 applies only to MCA and ROC filings, not to income tax or GST. Even after a strike-off, you must handle post-closure tax compliance for the relevant period and cancel your GST registration through its own separate process.
Is there a separate application form to register under CCFS 2026?
No. Unlike CFSS-2020, the MCA has not prescribed a separate opt-in form. You simply complete your pending filings on the MCA-21 (V3) portal within the scheme window and pay the correct concessional fees, keeping your DSC active to avoid rejection.
Tags:
Nebin Binoy
Written by Nebin Binoy

Nebin Binoy leads business incorporation coordination and compliance support operations at IncorpX. He works with startups, founders, and small businesses to streamline documentation, incorporation workflows, and ongoing business filing processes through IncorpX's professional network and support systems.