ROC Amnesty Schemes Compared: CFSS 2020 vs CCFS-2026

India has seen three major ROC amnesty schemes in the last eight years: CODS 2018, CFSS 2020, and now CCFS 2026. Each offered defaulting companies a time-limited window to clear overdue annual returns and financial statements at a fraction of the normal penalty cost. The Company Fresh Start Scheme 2020 waived 100% of accumulated additional fees during the COVID-19 pandemic. The Companies Compliance Facilitation Scheme 2026 waives 90% and adds two new pathways for dormant status and voluntary strike-off. For companies still carrying filing defaults in 2026, understanding exactly how these schemes compare is essential to making the right decision before the 15 July 2026 deadline.

Timeline of ROC Amnesty Schemes in India

The Ministry of Corporate Affairs has offered compliance relief schemes at irregular intervals, each responding to different circumstances. The table below maps every major ROC amnesty scheme from 2014 onwards, including the scope, fee relief offered, and the number of companies that benefited.

The pattern is clear: MCA amnesty schemes arrive every 2-4 years, each offering progressively more structured relief. CODS schemes charged a flat condonation fee regardless of default duration. CFSS 2020 shifted to a percentage-based model, waiving 100% of the accumulated additional fee. CCFS 2026 continues this percentage model at 90% while adding exit pathways that earlier schemes did not offer. Companies that missed CFSS 2020 now have one more chance under CCFS 2026, but at a slightly higher cost.

What Was the Company Fresh Start Scheme 2020?

The Company Fresh Start Scheme 2020 (CFSS 2020) was introduced by the MCA through General Circular 12/2020 dated 30 March 2020, exercising powers under Sections 403 and 460 of the Companies Act, 2013. The scheme was a direct response to the COVID-19 pandemic and the nationwide lockdown that made normal compliance activity impossible for most companies.

CFSS 2020 ran from 1 April 2020 to 30 September 2020 (initially set to end 30 September, later the immunity provisions were extended to 31 December 2020 via General Circular 30/2020). During this window, companies could file any overdue annual returns, financial statements, and other specified forms with the ROC without paying any additional (late) fees. The waiver was 100%: companies only paid the standard government filing fee for each form.

Key Features of CFSS 2020

• Fee Relief: 100% waiver on accumulated additional fees under Section 403
• Scope: All delayed filings under the Companies Act, 2013 and legacy filings under Companies Act, 1956
• Eligibility: All company types registered under the Companies Act, including Pvt Ltd, public, OPC, small company, and Section 8 companies
• Immunity: Immunity from prosecution for late filing of annual returns (Form MGT-7) and financial statements (Form AOC-4) if filed during the scheme period
• Legal Basis: General Circular 12/2020 read with Sections 403 and 460 of the Companies Act, 2013
• Exclusions: Companies against which final action for striking off under Section 248 was already completed; companies where management was taken over under Section 241/242; vanishing companies

CFSS 2020 was the most generous ROC amnesty scheme in Indian corporate history. Over 4.5 lakh companies filed overdue returns during the six-month window, clearing years of pending compliance backlogs. The scheme was particularly effective because the COVID-19 lockdown gave promoters and directors time to collate documents, engage professionals, and complete filings without the pressure of ongoing business operations.

What Is the Companies Compliance Facilitation Scheme 2026?

The Companies Compliance Facilitation Scheme 2026 (CCFS 2026) was introduced via General Circular 01/2026 dated 24 February 2026 under Sections 403 and 460 of the Companies Act, 2013 read with the Companies (Registration Offices and Fees) Rules, 2014. Unlike the emergency COVID-19 response that drove CFSS 2020, CCFS 2026 is a planned compliance facilitation measure designed to bring lakhs of defaulting companies back into compliance before MCA initiates a fresh round of enforcement action.

The scheme runs from 15 April 2026 to 15 July 2026, a 92-day window. Companies can regularise their filing defaults by paying only 10% of the accumulated additional fees that would otherwise be payable under the normal Rs. 100 per day penalty structure. In addition to regularisation, CCFS 2026 introduces two new exit pathways not available in earlier schemes.

Three Pathways Under CCFS 2026

1. Regularise and Continue: File all pending MGT-7, AOC-4, and other overdue forms at 10% of accumulated additional fees. Company returns to active, compliant status on MCA-21.
2. Dormant Status (Section 455): File Form MSC-1 at 50% of the normal filing fee to place the company on dormant status. Company remains on the register with minimal annual compliance (only Form MSC-3).
3. Voluntary Strike-Off: File Form STK-2 at 25% of the normal filing fee to permanently close the company. The company is removed from the MCA register and ceases to exist.

CFSS 2020 vs CCFS 2026: Full Comparison

The table below provides a side-by-side comparison across every parameter that matters when deciding how to use CCFS 2026 or evaluating what was available under CFSS 2020. The two schemes differ significantly on fee relief, pathways, and exit options.

Eligibility: Who Qualifies for Each Scheme

Both CFSS 2020 and CCFS 2026 cast a wide eligibility net, covering virtually all company types registered under the Companies Act. However, there are specific exclusions that every promoter must check before filing. The table below maps the eligibility criteria side by side.

Fee Savings: How Much Each Scheme Saves

The financial difference between CFSS 2020 and CCFS 2026 comes down to a single number: 100% vs 90%. While both schemes dramatically reduce the penalty burden, the 10% payable under CCFS 2026 adds up for companies with multi-year defaults. The table below shows exact savings for a company that defaulted on both MGT-7 and AOC-4 across different default durations.

Even at 90% waiver, CCFS 2026 delivers massive savings. A company with a 5-year default on two forms saves Rs. 3,28,500 compared to filing without any scheme. The standard government filing fee (the base fee for each form, typically Rs. 200-600) is payable in full under both schemes and is not included in the figures above.

Immunity Provisions: Prosecution and Penalty Protection

Both CFSS 2020 and CCFS 2026 include provisions that go beyond fee waivers. They offer conditional immunity from penalty proceedings, which is often more valuable than the fee savings themselves. The penalty exposure under Sections 92(5) and 137(3) of the Companies Act, 2013 can run into several lakh rupees per officer in default, separate from the additional filing fees.

CFSS 2020 Immunity

Under CFSS 2020, companies that filed overdue returns during the scheme period received immunity from prosecution for late filing. The scheme circular explicitly stated that no proceedings would be initiated for belated filings completed within the scheme window. This was a blanket immunity: it did not distinguish between companies that had already received notices and those that had not. The immunity extended to both the company and its officers in default.

CCFS 2026 Immunity

CCFS 2026 adopts a more structured immunity framework with three distinct scenarios:

1. No notice issued: If filings are completed before any adjudication notice is issued under Sections 92 or 137, proceedings are fully closed with no penalty.
2. Show-cause notice received, no order passed: If a show-cause notice has been received but no adjudication order has been passed, filing within 30 days of the notice results in full immunity.
3. Adjudication order already passed: If an adjudication order has been passed and the 30-day appeal window has lapsed, that specific penalty remains payable. The scheme does not override finalised adjudication orders.

CODS 2018: How the Earlier Scheme Compared

Before CFSS 2020, the primary compliance relief mechanism was the Condonation of Delay Scheme (CODS). The 2018 version allowed companies with overdue annual filings for FY 2014-15 to FY 2016-17 to apply for condonation by paying a flat fee of Rs. 30,000, regardless of the actual default duration. This was a fundamentally different model from the percentage-based waiver used by CFSS 2020 and CCFS 2026.

CODS 2018 had several limitations that the later schemes addressed:

• Fixed years covered: Only defaults for FY 2014-15 to FY 2016-17 were eligible; earlier or later defaults were excluded
• Flat fee regardless of default size: A company with a 1-year default and a company with a 3-year default both paid Rs. 30,000
• NCLT route for struck-off companies: Companies already struck off had to apply for restoration through NCLT at significant additional cost (Rs. 30,000-70,000)
• No exit pathways: No discounted dormant status or strike-off options were available
• Short initial window: Originally January to March 2018; extended to June 2018 after industry requests

For companies with small defaults (1 year or less on a single form), CODS 2018 was actually more expensive than CCFS 2026. A company with a 1-year default on one form would owe Rs. 3,650 under CCFS 2026 (10% of Rs. 36,500) compared to the flat Rs. 30,000 under CODS. However, for companies with very large multi-year defaults, CODS 2018's flat fee structure was occasionally more favourable. The percentage-based model used by CFSS 2020 and CCFS 2026 scales more fairly with the actual default size.

Which Scheme Should You Have Used (or Should You Use Now)?

If your company had defaults in 2020 and did not use CFSS 2020, the 100% waiver is no longer available. The question now is whether to use CCFS 2026 or risk waiting for a hypothetical future scheme. The answer depends on your company's situation, but for most companies, acting under CCFS 2026 is the correct decision.

Use CCFS 2026 Regularisation If:

• Your company is active or you plan to resume operations and need to bring the private limited company compliance record up to date
• You need a clean compliance record for bank loans, funding rounds, government tenders, or partnership agreements
• Directors face disqualification risk under Section 164(2) and need to clear the default immediately
• Accumulated additional fees are unaffordable without the 90% waiver

Use CCFS 2026 Dormant Status If:

• The company is inactive but you want to preserve the entity name, CIN, and registration for future use
• You anticipate restarting operations within 2-5 years and do not want to re-incorporate
• You want to reduce annual compliance to a single form (MSC-3) rather than the full set of MGT-7, AOC-4, and ADT-1

Use CCFS 2026 Strike-Off If:

• The company has no assets, no liabilities, and no intention of future use
• You want a permanent, clean exit from all ROC compliance obligations
• You want to avoid the higher cost and longer timeline of NCLT-ordered winding up

Common Mistakes When Filing Under Amnesty Schemes

Over 4.5 lakh companies filed under CFSS 2020, and the experience revealed several recurring mistakes that companies should avoid when using CCFS 2026. Learning from the 2020 experience can save significant time and money.

1. Filing without updated DIR-3 KYC: If any director's DIN is deactivated due to pending DIR-3 KYC, no MCA forms can be filed or digitally signed. Always complete DIR-3 KYC first. The reactivation fee is Rs. 5,000 per director.
2. Missing the correct form version: OPCs and small companies must file MGT-7A (not MGT-7). Filing the wrong form results in rejection and wastes time within the scheme window.
3. Not preparing financial statements before filing AOC-4: AOC-4 requires audited financial statements. Companies that start the AOC-4 process without completed financials face delays that push them past the deadline.
4. Waiting for the last week: During CFSS 2020, the MCA portal experienced severe slowdowns in September 2020 as lakhs of companies rushed to file. Payment gateway failures and form upload errors were widely reported. File in the first 30 days of the CCFS 2026 window.
5. Ignoring ADT-1: Companies that filed MGT-7 and AOC-4 under CFSS 2020 but forgot Form ADT-1 (Auditor Appointment) later discovered they were still technically in default. File all applicable forms, not just the annual returns.
6. Not obtaining board resolutions: Most filings require a board resolution authorising the filing. Companies without an active board (where directors have resigned or been disqualified) must first reconstitute the board before filing under the scheme.

How the LLP Amnesty Schemes Compare

While CFSS 2020 and CCFS 2026 apply only to companies, LLPs have parallel amnesty schemes with a different fee structure. Understanding the distinction is important for promoters who operate both company and LLP entities.

If you operate an LLP with overdue Form 8 or Form 11 filings, check our detailed guide on the LLP compliance requirements and the LLP Settlement Scheme 2026 to understand your filing obligations and savings.

Step-by-Step: Filing Under CCFS 2026

The filing process under CCFS 2026 follows the same MCA V3 portal workflow as regular filings, with the fee calculation automatically adjusted during the scheme period. Here is the complete process:

1. Step 1: Compliance Audit - Review your company's filing history on the MCA portal. Identify every overdue form: MGT-7, AOC-4, ADT-1, and any others. Use IncorpX's compliance health check for a complete assessment.
2. Step 2: Update DIR-3 KYC - Ensure all directors have active DINs. File DIR-3 KYC with Rs. 5,000 reactivation fee if any DIN is deactivated.
3. Step 3: Prepare Financial Statements - Get audited financial statements ready for each overdue year. This is a prerequisite for AOC-4 filing.
4. Step 4: Pass Board Resolutions - Approve the filing of overdue returns, adoption of financial statements, and appointment of auditor (if ADT-1 is also overdue).
5. Step 5: File Forms on MCA V3 - File all overdue forms through the MCA V3 portal. The system calculates additional fees at 10% automatically during the scheme window.
6. Step 6: Pay Fees - Pay the standard government filing fee plus 10% of accumulated additional fees for each form.
7. Step 7: Download Acknowledgements - Save SRN numbers and filing acknowledgements for every form filed. These are your proof of compliance for auditors, banks, and investors.

Summary

CFSS 2020 and CCFS 2026 represent the two most significant ROC amnesty schemes in Indian corporate history. CFSS 2020 offered a 100% waiver during an unprecedented pandemic; CCFS 2026 offers 90% with the added flexibility of dormant status and strike-off pathways. For companies that missed the 2020 window, CCFS 2026 is the last confirmed opportunity to clear years of filing defaults at a fraction of the normal penalty cost. The scheme runs until 15 July 2026 with no extension expected. Companies should identify their preferred pathway (regularise, go dormant, or close), complete document preparation, and file within the first 30 days to avoid portal congestion and ensure full penalty immunity. Whether you need to bring your private limited company compliance up to date, settle your LLP compliance under the parallel scheme, or explore the right exit option for an inactive entity, act before the window closes.