MCA 2026 Amnesty Scheme: 90% Additional Fee Waiver for Company Corrections and CCFS Filings
The Ministry of Corporate Affairs (MCA) introduced the Companies Compliance Facilitation Scheme 2026 (CCFS 2026) through General Circular No. 01/2026 dated 24 February 2026, offering defaulting companies a 90% waiver on accumulated ROC late filing fees. The scheme is active from 15 April 2026 to 15 July 2026 and provides three structured pathways: regularise pending filings at 10% of the additional fee, obtain dormant status at 50% of the normal fee, or close the company permanently via voluntary strike-off at 25% of the filing fee. This is the first comprehensive MCA amnesty since the COVID-era schemes of 2020.
If your company has pending Annual Returns (MGT-7) or Financial Statements (AOC-4), or if you want to close your private limited company, pause it as a dormant entity, or clear a multi-year compliance backlog, CCFS 2026 is the most cost-effective window to act. This blog covers every detail: fee calculations, covered forms, immunity provisions, eligibility, exclusions, the step-by-step process, and what happens if you miss the 15 July 2026 deadline.
- 90% waiver on accumulated additional fees - pay only 10% of the Rs. 100/day penalty
- Three pathways: Fix (regularise), Pause (dormant via MSC-1 at 50% fee), Close (STK-2 at 25% fee)
- Window: 15 April 2026 to 15 July 2026, strictly time-bound
- Immunity: Conditional protection from penalty proceedings under Sections 92 and 137
- Covers legacy forms: Defaults going back to 2010 and earlier under the Companies Act, 1956 are eligible
- Does NOT cover LLPs: Only companies under the Companies Act, 2013/1956 are eligible
What Is CCFS 2026?
The Companies Compliance Facilitation Scheme 2026 (CCFS 2026) is a one-time compliance amnesty introduced by MCA through General Circular No. 01/2026, exercising powers under Sections 460 and 403 of the Companies Act, 2013, read with the Companies (Registration Offices and Fees) Rules, 2014. It is designed to clean up the MCA-21 registry, reduce litigation exposure, and provide economical exit or dormancy pathways for inactive entities.
Under Section 403 of the Companies Act, 2013, delayed filing of annual returns and financial statements attracts an additional fee of Rs. 100 per day per form with no upper cap. This provision, effective from 1 July 2018, has resulted in exponentially rising penalty burdens, particularly for MSMEs, private companies, and inactive startups. MCA has acknowledged representations from stakeholders requesting relief and responded with CCFS 2026.
The circular notes that India has crossed 20 lakh active companies, with many new-age entrepreneurs, MSMEs, producer companies, and OPCs that have not completed annual compliances in time. CCFS 2026 is a structured mechanism to bring these entities back into compliance at a fraction of the normal cost.
- Scheme Period: 15 April 2026 to 15 July 2026 (no extension expected)
- Circular Reference: General Circular No. 01/2026 dated 24 February 2026 (F.No. Policy-02/2/2020-CL-V)
- Legal Basis: Sections 403 and 460 of the Companies Act, 2013
- Core Relief: Pay only 10% of accumulated additional fees - a 90% waiver
- Three Pathways: Regularise and continue; declare dormant under Section 455; close permanently via STK-2
CCFS 2026 is issued under Section 460 of the Companies Act, 2013, which authorises the Central Government to "remove difficulties" through orders for specific periods. The scheme does not change the law - it provides temporary relief from the fee structure prescribed under Section 403 and the Companies (Registration Offices and Fees) Rules, 2014.
Who Should Avail CCFS 2026?
CCFS 2026 is designed for companies with accumulated filing defaults that need an affordable path to fix, pause, or close the entity. You should act under this scheme if any of the following applies:
- You incorporated a private limited company, OPC, or small company but never commenced business operations and have not filed annual returns
- Your company was active for some years but has been inactive with no transactions and filings have lapsed for one or more years
- You want to close your company permanently and remove it from the MCA register at the lowest possible cost
- You want to declare your company dormant under Section 455 rather than close it, preserving the CIN for future reactivation
- You have received a show-cause notice from the ROC for non-filing of annual returns or financial statements
- Your accumulated late fee is so large that normal compliance is unaffordable without the 90% waiver
- You are a director concerned about disqualification under Section 164(2) due to the company's filing defaults
- You are an MSME, startup, or OPC with a compliance backlog that needs a cost-effective reset
Check Your CCFS 2026 Eligibility
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Get a Free Eligibility CheckHow Much Can You Save Under CCFS 2026?
The financial relief is substantial. The penalty for non-filing accumulates at Rs. 100 per day per form with no ceiling. Most companies default on at least two forms per year - MGT-7 (Annual Return) and AOC-4 (Financial Statements) - so the actual daily penalty is Rs. 200 per day across both forms.
| Default Period | Normal Additional Fee (per form) | Under CCFS 2026 (10%) | Savings Per Form |
|---|---|---|---|
| 1 Year (365 days) | Rs. 36,500 | Rs. 3,650 | Rs. 32,850 |
| 2 Years (730 days) | Rs. 73,000 | Rs. 7,300 | Rs. 65,700 |
| 3 Years (1,095 days) | Rs. 1,09,500 | Rs. 10,950 | Rs. 98,550 |
| 5 Years (1,825 days) | Rs. 1,82,500 | Rs. 18,250 | Rs. 1,64,250 |
| 8 Years (2,920 days) | Rs. 2,92,000 | Rs. 29,200 | Rs. 2,62,800 |
A private limited company that missed both MGT-7 and AOC-4 for 3 years normally owes over Rs. 2,19,000 in additional fees alone (2 forms x Rs. 1,09,500). Under CCFS 2026, this reduces to approximately Rs. 21,900. The standard government filing fee (not the additional fee) remains payable in full.
Based on our experience processing 500+ compliance regularisation cases, the most common scenario is a Pvt Ltd company with 3 to 5 years of unfiled MGT-7 and AOC-4. Without CCFS 2026, the penalty alone makes compliance unaffordable for most founders. The scheme effectively brings the cost back to a level where compliance is a practical business decision rather than a financial impossibility.
Three Pathways: Fix, Pause, or Close Your Company
CCFS 2026 is a structured compliance reset with three clear pathways. The right choice depends on your company's current status and future plans.
Pathway 1: Fix - Regularise Pending Filings and Continue
File all pending Annual Returns (MGT-7/MGT-7A) and Financial Statements (AOC-4) by paying only 10% of accumulated additional fees. Once accepted, the company's MCA-21 record is updated to full compliance. This is the right route if you plan to continue the business, seek bank loans or funding, bid for tenders, or enter contracts where compliance status is verified.
Pathway 2: Pause - Declare Dormant Under Section 455
If the company is inactive but you want to preserve the CIN, company name, or option to reactivate later, file Form MSC-1 at 50% of the normal fee. A dormant company stays on the MCA register with minimal annual compliance (only Form MSC-3 annually). To reactivate later, file Form MSC-4. This is the lowest-compliance option for keeping an inactive entity alive.
Pathway 3: Close - Voluntary Strike-Off via STK-2
For a clean, permanent exit, file Form STK-2 at 25% of the normal filing fee. The company is permanently removed from the MCA register, ceases to exist as a legal entity, and all future compliance obligations are eliminated. No court involvement, no winding-up proceedings - just an administrative closure. This is the most cost-effective way to close a private limited company.
| Pathway | Form | Fee Under CCFS | Outcome | Best For |
|---|---|---|---|---|
| Fix (Regularise) | MGT-7, AOC-4 and variants | 10% of additional fees | Company in full compliance | Active or soon-to-be-active companies |
| Pause (Dormant) | MSC-1 | 50% of normal fee | Registered with minimal compliance | Inactive companies to preserve and reactivate later |
| Close (Strike-Off) | STK-2 | 25% of normal fee | Permanently removed from register | Defunct companies with no future plans |
Not sure which pathway fits your situation? IncorpX assesses your company and recommends the most cost-effective route.
Talk to an ExpertForms Covered Under CCFS 2026
The scheme covers annual compliance forms under both the current Companies Act, 2013 and legacy forms from the Companies Act, 1956. Companies with very old compliance backlogs dating to 2010 and earlier can regularise all historical defaults under CCFS 2026.
Forms Under the Companies Act, 2013
- MGT-7 - Annual Return (all companies except OPCs and small companies)
- MGT-7A - Annual Return for OPCs and Small Companies
- AOC-4 - Financial Statements (Balance Sheet and Profit and Loss Account)
- AOC-4 CFS - Consolidated Financial Statements
- AOC-4 NBFC (Ind AS) - Financial Statements for NBFCs under Ind AS
- AOC-4 CFS NBFC (Ind AS) - Consolidated Financial Statements for NBFCs under Ind AS
- AOC-4 (XBRL) - Financial Statements in XBRL format
- ADT-1 - Intimation of Appointment or Change of Auditor
- FC-3 - Annual Accounts of Foreign Company with Indian place of business
- FC-4 - Annual Return of Foreign Company
Legacy Forms Under the Companies Act, 1956
- Form 20B - Annual Return (companies with share capital)
- Form 21A - Annual Return (companies without share capital)
- Form 23AC - Balance Sheet filing
- Form 23ACA - Profit and Loss Account filing
- Form 23AC-XBRL - Balance Sheet in XBRL format
- Form 23ACA-XBRL - Profit and Loss Account in XBRL format
- Form 66 - Compliance Certificate from a Company Secretary
- Form 23B - Intimation of Appointment of Statutory Auditor
The inclusion of legacy Companies Act, 1956 forms means companies with compliance defaults going back to 2010 and earlier can regularise all historical filings under CCFS 2026. This is significant for companies that have changed hands, where original founders lost track of filing obligations, or where compliance lapsed during the transition from Companies Act, 1956 to 2013.
Does CCFS 2026 Apply to LLPs?
No. CCFS 2026 does not apply to LLPs. The scheme defines "Company" as per clause (20) of Section 2 of the Companies Act, 2013, which covers entities incorporated under the Companies Act. Limited Liability Partnerships registered under the LLP Act, 2008 are a separate legal form and are not covered.
The covered forms (MGT-7, AOC-4, ADT-1, etc.) are all company-specific filings. LLP forms - Form 3, Form 4, Form 8, Form 11 - are governed by separate rules under the LLP Act and are not listed in the CCFS 2026 circular. No separate LLP amnesty or settlement scheme has been announced in 2026. The last LLP-specific scheme was the LLP Settlement Scheme 2020 (General Circular 06/2020).
If you own an LLP with overdue filings, read our detailed analysis: LLP Amnesty Scheme 2026: What LLP Owners Must Know. For LLP compliance assistance, contact IncorpX for a free compliance health check.
Immunity from Penalty Proceedings
CCFS 2026 provides a conditional immunity framework from penalty proceedings under Sections 92 and 137 of the Companies Act, 2013. The immunity operates based on the proviso to Section 454(3) of the Act. The level of protection depends on timing:
No Notice Issued Yet
If you file all required forms under the scheme before any notice is issued by the adjudicating officer, proceedings under Sections 92 and 137 shall be concluded and no penalty shall be levied. This is the strongest protection available. The entire matter is treated as fully and finally resolved.
Show-Cause Notice Received, No Order Passed
If a show-cause notice has been issued but no adjudication order has been passed, filing the required forms within 30 days of receiving the notice results in proceedings being concluded without penalty. Contact IncorpX immediately upon receiving any ROC notice - the 30-day clock starts from the date of receipt.
Adjudication Order Already Passed
If an adjudication order imposing a monetary penalty has already been passed and the 30-day window has elapsed, that specific penalty liability remains unaffected. CCFS 2026 does not provide retroactive relief against orders already issued. The scheme helps regularise filings going forward, but the adjudicated penalty must be paid separately.
Immunity for ADT-1, FC-3, FC-4, and Legacy Forms
For ADT-1, FC-3, FC-4, and legacy forms under the Companies Act, 1956, immunity against prospective penal action is available provided: (a) the forms are filed under the scheme, and (b) no prosecution has been initiated or adjudication proceedings commenced via show-cause notice before filing.
Filing before any notice = complete immunity. Filing within 30 days of notice = immunity maintained. Filing after an adjudication order = penalty still due. Every day of delay increases the risk of a notice being issued. If you have already received a ROC notice, act within the 30-day window immediately.
Who Cannot Avail CCFS 2026?
The scheme has specific exclusions. A preliminary eligibility check is essential before initiating any filing. The following companies are excluded from CCFS 2026:
- Companies against which final notice for compulsory strike-off under Section 248 (or previously Section 560 of Companies Act, 1956) has already been issued by the Registrar
- Companies that have already filed a voluntary strike-off application (STK-2) before the scheme period
- Companies that had already applied for dormant status (MSC-1) before the scheme's inception
- Companies dissolved pursuant to an amalgamation under the Act
- Vanishing companies as identified by SEBI or MCA
All other company types - private limited, public limited, OPC, small company, MSME, startup, listed company, foreign company, producer company, Nidhi company, Section 8 company - are eligible.
Based on our experience, the most common eligibility issue is companies that have already received a final Section 248 strike-off notice. If your company received such a notice, you cannot use CCFS 2026 directly. However, if the notice is in the initial stages (not final), you may still be eligible. IncorpX conducts a detailed eligibility assessment before any filing.
Director Disqualification: Why CCFS 2026 Is Urgent
Director disqualification under Section 164(2) of the Companies Act, 2013 is one of the most serious consequences of prolonged non-filing and one of the most compelling reasons to use CCFS 2026 immediately.
If a company fails to file annual returns or financial statements for 3 consecutive financial years, all directors of the company on the date of default are disqualified from being appointed or continuing as directors in any company in India for 5 years. This is not limited to the defaulting company - it affects all directorships across all entities.
Impact of Disqualification
- Cannot be appointed as a director in any new or existing company for 5 years
- Existing directorships in other companies are also at risk
- DIN is deactivated, blocking all MCA filings across all entities
- Banks and financial institutions may deny services based on disqualification status
- Removal of disqualification requires an NCLT petition even after filings are completed
Filing all overdue forms during CCFS 2026 stops the default clock and prevents disqualification from being triggered. For directors already at risk, completing filings under the scheme is the first step toward an NCLT petition for removal of disqualification.
What Happens If You Do Nothing?
Ignoring CCFS 2026 carries escalating consequences that the MCA circular explicitly addresses. Upon conclusion of the scheme, the circular states that "Registrars of Companies concerned shall take necessary action under the Act against the companies who have not availed this Scheme."
- Full penalty resumes: Rs. 100 per day per form additional fee continues accumulating with no cap from 16 July 2026
- ROC enforcement: Show-cause notices, adjudication proceedings under Sections 92 and 137, prosecutions, and compulsory strike-off under Section 248
- Director disqualification: Under Section 164(2) for 3+ consecutive years of default - 5-year ban on all directorships
- Loss of control: Compulsory strike-off by the Registrar is far more difficult to manage than voluntary strike-off under CCFS 2026
- Damaged creditworthiness: Non-compliant companies are flagged on MCA-21, affecting bank loans, tenders, and business contracts
MCA has historically increased enforcement after amnesty windows close. The rationale is clear: companies that did not file even when offered 90% fee relief are unlikely to file voluntarily. Expect accelerated strike-off notices and prosecution proceedings from Q3 2026 onwards.
Step-by-Step Process to Avail CCFS 2026
The process follows a structured sequence. Accurate document preparation and correct form selection are critical to avoid rejection.
- Identify all pending filings: Review your company's MCA-21 master data and filing history. List every form due but not filed, with precise default dates for each financial year
- Calculate fee exposure: For each overdue form, calculate default days x Rs. 100 = normal additional fee. Under CCFS 2026, you pay 10% of this amount plus the standard filing fee in full
- Choose your pathway: Regularise (MGT-7/AOC-4), dormant (MSC-1), or close (STK-2). Each has different documents, fees, and timelines
- Reactivate DINs if deactivated: If any director's DIN is deactivated due to non-filing of DIR-3 KYC, complete the KYC first with the Rs. 5,000 late fee. DIN reactivation takes 3 to 5 working days
- Prepare documents: CA-audited financial statements for each overdue year (for AOC-4), board resolutions, director KYC documents, and registered office proof
- File on MCA-21: Submit all forms and pay fees between 15 April 2026 and 15 July 2026. File in chronological order, starting with the oldest overdue year. File AOC-4 before MGT-7 for each financial year
- Track status: Monitor SRN status of every filed form. Respond to any ROC observations within the specified timeline (usually 15 days)
Regularisation filings (MGT-7, AOC-4) are processed within a few working days once documents are complete. Dormant status (MSC-1) is processed quickly. Voluntary strike-off (STK-2) takes 2 to 4 months due to the mandatory public notice period. If company closure is your goal, start filing immediately after 15 April 2026.
Get CCFS 2026 Filing Done Right
IncorpX handles end-to-end CCFS 2026 filing: eligibility check, fee calculation, document preparation, MCA submission, and post-filing tracking. Flat-fee pricing with no surprises.
Start CCFS 2026 FilingCompliance After CCFS 2026: What Changes?
Your ongoing obligations depend on the pathway you chose. The table below summarises annual compliance requirements post-scheme.
| Requirement | Active Company (Regularised) | Dormant Company (MSC-1) | Struck-Off Company (STK-2) |
|---|---|---|---|
| Annual Return (MGT-7/MGT-7A) | Required every year within 60 days of AGM | Not required (replaced by MSC-3) | Not applicable |
| Financial Statements (AOC-4) | Required every year within 30 days of AGM | Not required | Not applicable |
| Annual Dormancy Form | Not applicable | MSC-3 required annually | Not applicable |
| Statutory Audit | Required annually | Not required during dormant period | Not applicable |
| Board Meetings | Minimum 4 per year (2 for small companies) | Not required | Not applicable |
| Reactivation | Already active | File Form MSC-4 with ROC | Not possible - closure is permanent |
| Annual Compliance Cost | Rs. 15,000 to Rs. 50,000/year | Rs. 3,000 to Rs. 8,000/year | Nil |
Need ongoing annual compliance management after CCFS 2026? IncorpX offers annual compliance packages starting at Rs. 9,999.
View Annual Compliance PlansCCFS 2026 vs Companies Fresh Start Scheme 2020
MCA has offered similar amnesty schemes before. The most recent comparable scheme was the Companies Fresh Start Scheme 2020 (CFSS 2020), introduced during the COVID-19 pandemic. Here is how the two compare:
| Feature | CFSS 2020 | CCFS 2026 |
|---|---|---|
| Notification | General Circular 12/2020 | General Circular 01/2026 |
| Additional Fee Waiver | 100% waiver (complete) | 90% waiver (pay 10%) |
| Dormant Status Fee | Not explicitly discounted | 50% of normal MSC-1 fee |
| Strike-Off Fee | Not explicitly discounted | 25% of normal STK-2 fee |
| Context | COVID-19 pandemic relief | Periodic compliance reset |
| Penalty Immunity | Conditional under Section 454(3) | Conditional under Section 454(3) |
CFSS 2020 was more generous with a complete fee waiver, but it was an exceptional measure during pandemic-era disruptions. CCFS 2026 provides a 90% waiver, which still translates to savings of lakhs for companies with multi-year defaults. The additional dormant status and strike-off fee concessions make CCFS 2026 more versatile for companies seeking exit or pause options.
CCFS 2026 Quick Reference
| Parameter | Details |
|---|---|
| Scheme Name | Companies Compliance Facilitation Scheme 2026 (CCFS 2026) |
| Announced By | Ministry of Corporate Affairs (MCA), Government of India |
| Circular Reference | General Circular No. 01/2026 dated 24 February 2026 (F.No. Policy-02/2/2020-CL-V) |
| Legal Basis | Sections 403 and 460 of the Companies Act, 2013 |
| Scheme Opens | 15 April 2026 |
| Scheme Closes | 15 July 2026 (strictly time-bound) |
| Additional Fee Waiver | 90% - pay only 10% of accumulated additional fees |
| Dormant Status Fee (MSC-1) | 50% of normal filing fee |
| Strike-Off Fee (STK-2) | 25% of normal filing fee |
| Normal Filing Fee | Payable in full (not waived) |
| Penalty Immunity | Under Sections 92/137 - conditional on timing of filing vs notice |
| Excluded | Section 248 final notice issued; already filed STK-2/MSC-1; dissolved via amalgamation; vanishing companies |
| Forms (Companies Act, 2013) | MGT-7, MGT-7A, AOC-4 (all variants), ADT-1, FC-3, FC-4 |
| Forms (Companies Act, 1956) | 20B, 21A, 23AC, 23ACA, 23AC-XBRL, 23ACA-XBRL, 66, 23B |
| Eligible Entities | All companies (Pvt Ltd, Public, OPC, Small, MSME, Startup, Foreign, Section 8, Nidhi, Producer) |
| NOT Eligible | LLPs (governed by LLP Act, 2008 - separate statute) |
Why Act Through IncorpX?
IncorpX has helped hundreds of founders, MSMEs, and businesses across India handle MCA compliance - from clearing annual return backlogs and responding to ROC notices to closing private limited companies and obtaining dormant status. CCFS 2026 requires careful eligibility assessment, accurate fee calculation, correct form selection, and error-free filing. Here is what you get:
- Free eligibility check: We verify whether your company qualifies for CCFS 2026 and identify all outstanding forms before any process begins
- Precise fee calculation: We pull your company's complete MCA filing history and calculate the exact amount payable under the scheme for every defaulted form
- End-to-end filing: Qualified Company Secretaries and Chartered Accountants prepare all documents, file on MCA-21, and track every submission
- Pathway advisory: We assess whether to regularise, declare dormant, or close - and recommend the most cost-effective route
- Priority STK-2 processing: We begin company closure processing immediately after 15 April 2026 to ensure completion before the scheme closes
- ROC notice handling: If you have received a show-cause notice, we respond on your behalf and ensure filings are completed within the 30-day immunity window
- Transparent flat-fee pricing: No hidden charges, no percentage-based billing
Summary
The Companies Compliance Facilitation Scheme 2026 (CCFS 2026) provides a 90% waiver on accumulated ROC late filing fees for companies from 15 April to 15 July 2026. Three pathways are available: regularise pending filings at 10% of the penalty, obtain dormant status at 50% of the normal fee, or close the company via voluntary strike-off at 25% of the fee. Conditional immunity from penalty proceedings under Sections 92 and 137 is available if filings are completed before an adjudication notice is issued or within 30 days of receiving one. The scheme covers all company types under the Companies Act, 2013 and 1956 - but does not cover LLPs. The cost of inaction after 15 July 2026 will always exceed the cost of acting today.
Start Your CCFS 2026 Filing Today
IncorpX handles end-to-end CCFS 2026 compliance: eligibility check, fee calculation, CA/CS certified filings, and MCA submission. Flat-fee pricing, no surprises.
File Under CCFS 2026Frequently Asked Questions
What is the Companies Compliance Facilitation Scheme 2026?
How do I close my private limited company using CCFS 2026?
Can I get a waiver of penalties for non-filing of annual returns?
How can I activate my dormant company or bring it back to active status?
What is the last date for availing CCFS 2026?
How much is the fee reduction under CCFS 2026?
Can I close my company if it never started operations?
What is the difference between strike-off, dormant status, and regularisation?
What forms are covered under CCFS 2026?
Will I get immunity from penalties if I file under CCFS 2026?
Who cannot avail CCFS 2026?
Does CCFS 2026 apply to LLPs?
Can directors avoid disqualification by using CCFS 2026?
How long does it take to close a company under CCFS 2026?
Do I still need to pay the normal ROC filing fee under CCFS 2026?
Can a company with pending GST or income tax issues use CCFS 2026?
Is CCFS 2026 applicable to OPCs, MSMEs, and startups?
What is the penalty for not filing ROC returns after CCFS 2026 ends?
How is CCFS 2026 different from the Companies Fresh Start Scheme 2020?
What documents are needed to file under CCFS 2026?
Can I file for CCFS 2026 if I received a ROC notice?
