ROC Filing Amnesty Scheme 2026 for Companies and LLPs
Step-by-step guide to file under CCFS 2026. 90% waiver on ROC late fees, three pathways (fix, pause, close), forms covered, immunity, eligibility, and savings.
Documents Required
- Audited financial statements (Balance Sheet, Profit and Loss Account, Cash Flow Statement) for each overdue financial year
- Board resolution authorising the filing of overdue forms
- Certificate of Incorporation and CIN of the company
- PAN Card and Aadhaar of all directors for DIR-3 KYC reactivation (if DIN deactivated)
- Annual return data including member details, shareholding, and changes during each overdue year
- Digital Signature Certificate (DSC) of the authorised signatory (director and statutory auditor)
- Auditor appointment letter and consent for ADT-1 filing (if applicable)
- Special resolution and indemnity bond for STK-2 (voluntary strike-off pathway)
- Special resolution and NOC from secured creditors for MSC-1 (dormant status pathway)
Tools & Prerequisites
- Class 3 Digital Signature Certificate (DSC) for the authorised director and statutory auditor
- Active MCA V3 portal account at mca.gov.in with verified credentials
- Accounting software such as Tally or Zoho Books for generating financial statements for overdue years
- Chartered Accountant (CA) for statutory audit of overdue financial years
- Company Secretary (CS) for certification of MGT-7 if paid-up capital exceeds Rs. 10 crore or turnover exceeds Rs. 50 crore
The Ministry of Corporate Affairs (MCA) register carries lakhs of companies with pending annual filings. Non-filing accumulates additional fees at Rs. 100 per day per form with no cap under Section 403 of the Companies Act, 2013. A company that missed both MGT-7 and AOC-4 for three years faces over Rs. 2 lakh in additional fees alone. The Companies Compliance Facilitation Scheme 2026 (CCFS 2026), introduced via General Circular No. 01/2026 dated 24 February 2026, addresses this by offering a 90% waiver on accumulated additional fees and three structured pathways: regularise pending filings, obtain dormant status, or close the company permanently.
This guide covers the complete filing process: eligibility verification, pathway selection, fee calculations, form-by-form instructions, documents required, common mistakes, savings examples, post-filing actions, and professional role guidance. Everything needed to clear years of compliance backlog during the CCFS 2026 window (15 April to 15 July 2026). For a concise overview of the scheme itself, read our CCFS 2026: MCA Amnesty Scheme for Companies blog.
Key Takeaways
- Scheme: Companies Compliance Facilitation Scheme 2026 (CCFS 2026), General Circular No. 01/2026
- Window: 15 April 2026 to 15 July 2026, strictly time-bound
- Fee relief: Pay only 10% of accumulated additional fees (90% waiver on the Rs. 100/day per form penalty)
- Three pathways: Fix (regularise at 10%), Pause (dormant via MSC-1 at 50% fee), Close (strike-off via STK-2 at 25% fee)
- Covered forms: MGT-7, MGT-7A, AOC-4 (all variants), ADT-1, FC-3, FC-4 + legacy 1956 Act forms
- Immunity: Conditional protection from penalty proceedings under Sections 92 and 137
- Filing order: Oldest year first; AOC-4 before MGT-7; reactivate DINs first if deactivated
- NOT covered: LLPs, companies with final Section 248 notice, already filed STK-2/MSC-1, vanishing companies
What Is CCFS 2026?
The Companies Compliance Facilitation Scheme 2026 (CCFS 2026) is a one-time compliance amnesty issued by MCA 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 register, reduce litigation exposure for the government, and provide cost-effective exit or recovery pathways for inactive entities.
Under Section 403, 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 created exponentially rising penalty burdens. MCA has acknowledged that India has crossed 20 lakh active companies, with many MSMEs, startups, producer companies, and OPCs that have not completed annual compliances in time. CCFS 2026 is the structured response.
The scheme does not change the law itself. It provides temporary relief from the fee structure for a fixed period. After 15 July 2026, the full penalty structure resumes and MCA has stated that Registrars will initiate enforcement against companies that remain in default.
- Circular: General Circular No. 01/2026 dated 24 February 2026 (F.No. Policy-02/2/2020-CL-V)
- Legal authority: Sections 403 and 460, Companies Act, 2013
- Window: 15 April 2026 to 15 July 2026
- Core relief: 90% waiver on accumulated additional fees (pay only 10%)
CCFS 2026 applies only to companies as defined under Section 2(20) of the Companies Act, 2013. LLPs registered under the LLP Act, 2008 are not covered. No separate LLP amnesty has been announced in 2026. For LLP compliance options, read our LLP Amnesty Scheme 2026 analysis.
History of MCA Amnesty Schemes
MCA has introduced amnesty schemes at irregular intervals when non-compliant entities on the register reach unsustainable levels. Each scheme had different terms.
| Scheme | Year | Duration | Fee Treatment | Applicable To |
|---|---|---|---|---|
| Condonation of Delay Scheme (CODS) | 2018 | 1 January to 1 May 2018 | Reduced additional fee for delayed annual filings | Companies |
| Companies Fresh Start Scheme (CFSS) | 2020 | 1 April to 30 September 2020 | Full waiver of additional fees (zero additional fee) | Companies |
| LLP Settlement Scheme | 2020 | 1 April to 30 September 2020 | Full waiver of additional fees for LLPs | LLPs |
| CCFS 2026 | 2026 | 15 April to 15 July 2026 | 90% waiver (pay 10%) + MSC-1 at 50% + STK-2 at 25% | Companies only |
CFSS 2020 was more generous with a complete fee waiver, but it was an exceptional pandemic-era measure. CCFS 2026 provides a 90% waiver, which still translates to savings of lakhs for multi-year defaults. The additional dormant status and strike-off fee concessions make CCFS 2026 more versatile for companies seeking exit or pause options.
Based on our experience processing amnesty filings during every MCA scheme since CODS 2018: MCA consistently increases enforcement after amnesty windows close. The rationale is clear - companies that did not file even with 90% relief are unlikely to file voluntarily. Post-CFSS 2020, MCA accelerated Section 248 strike-off proceedings. Expect the same pattern from Q3 2026.
Three Pathways: Fix, Pause, or Close
CCFS 2026 is a structured compliance reset with three distinct pathways. Each has different forms, fees, outcomes, and timelines.
Pathway 1: Fix - Regularise and Continue
File all pending MGT-7/MGT-7A (annual returns) and AOC-4 (financial statements) by paying only 10% of accumulated additional fees. Once accepted, the company's MCA-21 compliance record is updated to full good standing. Choose this pathway if:
- The company is operational or will resume operations
- You need clean compliance status for bank loans, funding, or government tenders
- Directors want to prevent or resolve disqualification under Section 164(2)
Pathway 2: Pause - Dormant Status Under Section 455
File Form MSC-1 at 50% of the normal filing fee to declare the company dormant. A dormant company stays on the MCA register with minimal annual compliance (only Form MSC-3). The CIN and company name are preserved for future reactivation via Form MSC-4. Choose this pathway if:
- The company is inactive but you want to preserve it for a future project
- You want to protect the company name and CIN
- You want the lowest ongoing compliance burden without permanent closure
Pathway 3: Close - Voluntary Strike-Off via STK-2
File Form STK-2 at 25% of the normal filing fee for permanent closure. The company is removed from the MCA register and ceases to exist as a legal entity. All future compliance obligations are eliminated. Choose this pathway if:
- The company is defunct with no plans for future use
- You want a clean, permanent exit with no ongoing obligations
- You want to close your private limited company at the lowest possible cost
| Pathway | Form | CCFS Fee | Outcome | Processing Time |
|---|---|---|---|---|
| Fix (Regularise) | MGT-7, AOC-4, ADT-1 | 10% of additional fees | Full compliance | A few working days per form |
| Pause (Dormant) | MSC-1 | 50% of normal fee | Registered, minimal compliance | A few weeks |
| Close (Strike-Off) | STK-2 | 25% of normal fee | Permanently removed | 2 to 4 months |
Not Sure Which Pathway Is Right?
IncorpX assesses your company status and recommends the most cost-effective route under CCFS 2026.
Get a Free Eligibility CheckWho Is Eligible for CCFS 2026?
Eligible Entities
- Private Limited Companies with pending annual filings (AOC-4, MGT-7, ADT-1)
- Public Limited Companies with overdue annual returns or financial statements
- One Person Companies (OPCs) filing MGT-7A and AOC-4
- Small Companies as defined under Section 2(85)
- Section 8 Companies (non-profit entities) with compliance backlogs
- Nidhi Companies under Section 406
- Producer Companies registered under Part IXA of the Companies Act, 1956
- Foreign Companies with pending FC-3 and FC-4 filings
- Dormant Companies registered under Section 455 with overdue annual forms
- Active-non-compliant companies flagged by ROC for overdue filings
- Companies with legacy defaults under the Companies Act, 1956
Excluded from CCFS 2026
- Companies against which final notice for compulsory strike-off under Section 248 has been issued
- Companies that already filed STK-2 (voluntary strike-off) before the scheme period
- Companies that already applied for dormant status (MSC-1) before the scheme
- Companies dissolved through amalgamation
- Vanishing companies listed by SEBI or MCA
- LLPs registered under the LLP Act, 2008 (separate statute, not covered)
If your company has received any notice under Section 248, verify whether it is a first notice (initial strike-off notice) or a final notice. Only companies with a final Section 248 notice are excluded. Companies at the initial notice stage may still be eligible. IncorpX conducts a detailed eligibility assessment before any filing.
Forms Covered Under CCFS 2026
The scheme covers annual compliance forms under the Companies Act, 2013 and legacy forms from the Companies Act, 1956. The table below lists all covered forms with their purpose and normal due dates.
| Form | Purpose | Applicable To | Normal Due Date |
|---|---|---|---|
| MGT-7 | Annual Return | All companies (except OPC/Small Co.) | 60 days from AGM |
| MGT-7A | Annual Return (simplified) | OPCs and Small Companies | 60 days from AGM |
| AOC-4 | Financial Statements | All companies | 30 days from AGM |
| AOC-4 CFS | Consolidated Financial Statements | Companies with subsidiaries | 30 days from AGM |
| AOC-4 XBRL | Financial Statements in XBRL | Listed cos, capital Rs. 5 Cr+ or turnover Rs. 100 Cr+ | 30 days from AGM |
| AOC-4 NBFC (Ind AS) | NBFC Financial Statements | NBFCs under Ind AS | 30 days from AGM |
| AOC-4 CFS NBFC (Ind AS) | NBFC Consolidated Financials | NBFCs with subsidiaries | 30 days from AGM |
| ADT-1 | Auditor Appointment Notice | All companies | 15 days from AGM |
| FC-3 | Annual Accounts (Foreign Co.) | Foreign companies in India | Within 6 months of FY end |
| FC-4 | Annual Return (Foreign Co.) | Foreign companies in India | 60 days from FY end |
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 / 23ACA - Balance Sheet and Profit and Loss Account
- Form 23AC-XBRL / 23ACA-XBRL - XBRL format financial statements
- Form 66 - Compliance Certificate from Company Secretary
- Form 23B - Intimation of Appointment of Statutory Auditor
The inclusion of Companies Act, 1956 forms means companies with defaults going back to 2010 and earlier can regularise all historical filings under CCFS 2026. This is significant for companies that changed hands or where compliance lapsed during the transition period between the 1956 and 2013 Acts.
Savings Calculator: How Much You Save
The additional fee under Section 403 is Rs. 100 per day per form with no cap (effective 1 July 2018). Under CCFS 2026, you pay 10% of this accumulated amount. The standard government filing fee remains payable in full.
Savings Per Form by Default Period
| 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 |
Scenario 1: Pvt Ltd - 3 Years of Pending MGT-7 and AOC-4
| Component | Without CCFS (Rs.) | Under CCFS 2026 (Rs.) |
|---|---|---|
| Additional fee: AOC-4 x 3 years (1,095 days each) | 3,28,500 | 32,850 |
| Additional fee: MGT-7 x 3 years (1,095 days each) | 3,28,500 | 32,850 |
| Standard filing fee (6 forms) | Approx. 1,800 | Approx. 1,800 |
| Total Government Fee | 6,58,800 | 67,500 |
| Savings | Rs. 5,91,300 (90% reduction) | |
Scenario 2: OPC - 5 Years of Pending AOC-4 and MGT-7A
| Component | Without CCFS (Rs.) | Under CCFS 2026 (Rs.) |
|---|---|---|
| Additional fee: AOC-4 x 5 years | 9,12,500 | 91,250 |
| Additional fee: MGT-7A x 5 years | 9,12,500 | 91,250 |
| Standard filing fee (10 forms) | Approx. 2,000 | Approx. 2,000 |
| DIN reactivation (1 director) | 5,000 | 5,000 |
| Total Government Fee | 18,32,000 | 1,89,500 |
| Savings | Rs. 16,42,500 (90% reduction) | |
The DIN reactivation fee of Rs. 5,000 per director is a fixed charge and is not reduced under CCFS 2026. Professional fees for CA and CS services are separate from government filing fees.
These calculations use individual default-day counts per form. In practice, the MCA portal auto-calculates the exact fee for each form based on the filing date. The actual amount may vary slightly depending on the precise due date and filing date for each financial year. IncorpX calculates the exact payable amount before any filing begins.
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).
Tier 1: No Notice Issued (Strongest Protection)
If all required forms are filed under the scheme before any notice is issued by the adjudicating officer, proceedings under Sections 92 and 137 shall be deemed concluded and no penalty shall be levied. This is the cleanest protection available and the primary reason to act early.
Tier 2: 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. The 30-day clock starts from the date of receipt of the notice.
Tier 3: 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.
Immunity for ADT-1, FC-3, FC-4, and Legacy Forms
For these forms, immunity against prospective penal action is available provided: (a) forms are filed under the scheme, and (b) no prosecution has been initiated or adjudication proceedings commenced via show-cause notice before filing.
Every day of delay increases the risk of a notice being issued. Once a notice arrives, you have only 30 days to file and maintain immunity. Filing before any notice is received provides the strongest, most complete protection under CCFS 2026.
Step-by-Step Filing Process
Follow this sequence to file all overdue forms correctly during the CCFS 2026 window. The process is identical to normal ROC filing except the MCA portal applies the reduced additional fee.
Step 1: Verify Eligibility on MCA Portal
Go to www.mca.gov.in and log in to the MCA V3 portal. Check the company status by CIN. It must show as Active or Active-non-compliant. If it shows Struck Off, you cannot directly use CCFS 2026. Check the compliance status dashboard for a list of all overdue filings and verify the company is not in any excluded category (Section 248 final notice, already filed STK-2, etc.).
Step 2: Reactivate Deactivated DINs
Check whether any director's DIN is deactivated due to non-filing of DIR-3 KYC. A deactivated DIN prevents the director from digitally signing any MCA form, blocking all filings. File DIR-3 KYC for each deactivated director with PAN, Aadhaar, mobile, and email verification. Pay the Rs. 5,000 reactivation fee per director. DIN reactivation takes 3 to 5 working days. Complete this before starting any annual filings.
Step 3: Choose Your Pathway
Based on the company's status and your future plans:
- Fix: If continuing operations, file all pending MGT-7 and AOC-4 at 10% additional fee
- Pause: If preserving the company, file MSC-1 at 50% of normal fee for dormant status
- Close: If shutting down permanently, file STK-2 at 25% of normal fee. Note: STK-2 takes 2 to 4 months, so start immediately after 15 April 2026
Step 4: Engage a CA for Audit of Overdue Years
Each financial year with pending AOC-4 requires audited financial statements. Engage a Chartered Accountant to prepare and audit the Balance Sheet, Profit and Loss Account, notes to accounts, and audit report for each overdue year. If books of accounts are incomplete, reconstruct them from bank statements, GST returns (GSTR-3B summaries), and TDS certificates (Form 26AS/AIS). For companies with nil transactions, the CA prepares nil financial statements showing only share capital and minimal expenses.
Step 5: Prepare Form Data Year-Wise
Compile the data required for each form and each financial year:
- AOC-4: Audited financial statements, board resolution, auditor's report, CIN, turnover, profit/loss figures
- MGT-7/MGT-7A: Registered office, principal business activity, shareholder list, director details, share capital structure, changes during the year
- ADT-1: Auditor name, membership number, firm registration, appointment date, tenure
- MSC-1: Special resolution, NOC from secured creditors, board resolution
- STK-2: Special resolution, indemnity bond, director affidavit, statement of accounts (not older than 30 days)
Step 6: File Forms in Chronological Order
Start from the oldest overdue financial year and work forward. Within each year:
- File AOC-4 first (financial statements)
- File MGT-7/MGT-7A second (annual return) - this references the filed AOC-4
- File ADT-1 and other pending forms for that year
This order is mandatory. Attempting to file MGT-7 before AOC-4 for the same year triggers a validation error on the MCA portal. Complete all forms for one financial year before moving to the next.
Step 7: Verify Fee and Pay
The MCA portal auto-calculates the fee during the CCFS 2026 window, applying the 10% additional fee rate. Verify the displayed amount matches your calculation. Pay through the MCA payment gateway via net banking, credit card, or debit card. Keep the payment receipt.
Step 8: Affix DSC and Submit
After payment, affix the Digital Signature Certificate of the authorised director. For AOC-4, the statutory auditor also affixes their DSC. For MGT-7, a Company Secretary in practice affixes their DSC if the company's paid-up capital exceeds Rs. 10 crore or turnover exceeds Rs. 50 crore. Review the form and click Submit. Note the SRN generated for each form.
Step 9: Track Approval and Handle Observations
The ROC reviews and approves forms within 7 to 15 working days. Monitor the SRN status under View Submitted Forms. If the ROC raises observations (Resubmission Required), address deficiencies and resubmit within the specified timeline (usually 15 days). If the CCFS 2026 window is still open, resubmissions retain the reduced fee.
Plan 2 to 3 working days per form for preparation and submission. For companies with 3+ years of backlog, start within the first week of the scheme window (15 April 2026). STK-2 for company closure takes 2 to 4 months from filing to gazette notification. Do not wait until June or July if closure is the goal.
Form-by-Form Filing Instructions
Each form has specific fields, attachments, and certification requirements. Below are step-by-step instructions for the most commonly filed forms.
Filing AOC-4 (Financial Statements)
- MCA V3 Portal > Company Filing > Select Form AOC-4
- Enter CIN - portal auto-populates company name and registered office
- Select the financial year (e.g., 2022-23)
- Enter financial data: turnover, paid-up capital, net worth, total borrowings, profit/loss
- Upload: audited Balance Sheet (PDF), Profit and Loss Account (PDF), notes to accounts, auditor's report, board resolution
- Portal calculates normal fee + 10% additional fee under CCFS 2026
- Pay via payment gateway
- Director affixes DSC > CA affixes DSC > Submit
- Note SRN and download receipt
Companies required to file in XBRL format (listed companies, paid-up capital Rs. 5 crore+ or turnover Rs. 100 crore+) use AOC-4 XBRL. The process is similar but requires generating the XBRL instance document using MCA's filing tool or commercial XBRL software. XBRL filing adds 2 to 3 working days to the preparation timeline per financial year and requires specialised software that most companies will need their CA or CS to provide.
Filing MGT-7/MGT-7A (Annual Return)
- MCA V3 Portal > Company Filing > Select MGT-7 or MGT-7A
- Enter CIN and select the relevant financial year
- Fill in registered office address, principal business activity code, company category
- Enter share capital details: authorised, issued, subscribed, paid-up
- List all members/shareholders with holdings as on last day of FY
- List all directors with DIN, appointment dates, changes during the year
- Provide details of meetings held (board meetings, AGM)
- Upload CS certificate (Form MGT-8) if applicable
- Pay CCFS 2026 reduced fee > Affix DSC > Submit
Filing ADT-1 (Auditor Appointment)
- MCA V3 Portal > Company Filing > Select ADT-1
- Enter CIN and auditor details: name, membership number, firm registration
- Specify appointment date and tenure of auditor
- Upload board resolution and auditor consent letter
- Pay reduced fee > Affix DSC > Submit
Filing MSC-1 (Dormant Status Application)
- MCA V3 Portal > Company Filing > Select MSC-1
- Enter CIN and confirm the company has had no significant accounting transactions for two immediately preceding financial years (or since incorporation if younger)
- Upload special resolution of members, NOC from secured creditors, board resolution
- Pay 50% of normal MSC-1 filing fee under CCFS 2026
- Affix DSC > Submit
Filing STK-2 (Voluntary Strike-Off)
- MCA V3 Portal > Company Filing > Select STK-2
- Enter CIN and confirm the company has no assets, no pending liabilities, and no ongoing operations
- Upload: special resolution, indemnity bond from all directors, affidavit confirming no pending liabilities, statement of accounts (not older than 30 days before filing), NOC from regulatory bodies (EPFO, ESIC, GST if applicable)
- Pay 25% of normal STK-2 filing fee under CCFS 2026
- Affix DSC > Submit
- ROC publishes public notice. After mandatory notice period (no objections received), company is struck off and gazette notification is published
Need professional assistance with CCFS 2026 filings? IncorpX handles the complete process from audit to MCA submission.
Get CCFS 2026 Filing DoneDocuments Required for CCFS 2026 Filing
Documents depend on the pathway chosen. Missing documents cause delays and may push filings beyond the 15 July deadline.
For Regularisation (MGT-7 and AOC-4)
- Audited Balance Sheet for each overdue financial year
- Audited Profit and Loss Account for each overdue financial year
- Cash Flow Statement (not required for OPCs and small companies)
- Notes to Accounts
- Independent Auditor's Report for each year
- Board resolution approving financial statements and authorising filing
- Minutes of AGM (or board resolution in lieu of AGM for OPCs)
- List of shareholders with shareholding details as on last day of each FY
- List of all directors with DIN, appointment dates, changes during each year
- Certificate of Incorporation and CIN
- Class 3 DSC of authorised director and statutory auditor
For Dormant Status (MSC-1)
- Special resolution of members approving dormant status
- NOC from all secured creditors
- Board resolution
- Certificate confirming no significant accounting transactions for 2 preceding FYs
- Class 3 DSC of authorised director
For Voluntary Strike-Off (STK-2)
- Special resolution of members approving strike-off
- Indemnity bond from all directors
- Affidavit from directors confirming no pending liabilities
- Statement of accounts not older than 30 days before filing
- NOC from EPFO, ESIC (if applicable)
- GST registration cancellation order (if GST registered)
- Income tax clearance or latest ITR filing acknowledgement
- Class 3 DSC of authorised director
Common Mistakes During CCFS 2026 Filing
Mistakes during amnesty filing waste time, cause rejections, and may push filings beyond the deadline. Avoid these errors based on patterns observed across past amnesty windows.
Filing Annual Returns Before Financial Statements
The MCA portal requires AOC-4 to be filed before MGT-7 for the same financial year. The annual return references the filed financial statements. Filing MGT-7 first triggers a system error. Always file AOC-4 first, wait for SRN generation, then file MGT-7.
Ignoring DIN Deactivation
Directors with deactivated DINs cannot sign any MCA forms. The most common cause is non-filing of DIR-3 KYC by the 30 September deadline. This becomes a blocking issue because no form can be submitted without an active director's DSC. Reactivate all DINs first.
Mismatched Data Between AOC-4 and MGT-7
Turnover, profit/loss, and share capital figures in MGT-7 must exactly match the financial statements filed in AOC-4 for the same year. Even a rounding difference triggers a ROC observation and resubmission notice. Use the exact figures from audited financials in both forms.
Using an Expired DSC
DSCs have a validity period of 2 to 3 years. If the DSC expired during the non-compliance period, obtain a new Class 3 DSC before filing. Cost: Rs. 800 to Rs. 1,500, issued within 1 to 3 working days. Register the new DSC on the MCA V3 portal before submitting forms.
Filing Only the Most Recent Overdue Year
Some companies file only the latest year and skip older years, thinking partial compliance is sufficient. The CCFS 2026 window is the best time to clear the entire backlog because the 90% waiver applies to all overdue years. Filing only one year leaves the company non-compliant and at risk for older defaults.
Waiting Until the Last Week
During the final week of every past amnesty scheme, the MCA portal experienced heavy traffic, slow processing, and intermittent errors. Begin filing within the first month of the window. MCA does not extend deadlines for portal congestion on the filer's end.
If a form is rejected and requires resubmission, you need time to correct and refile. Starting early ensures you have this buffer. A form rejected in the last week of July may not be resubmittable within the CCFS 2026 window.
Director Disqualification and CCFS 2026
Director disqualification under Section 164(2) of the Companies Act, 2013 is one of the most serious consequences of prolonged non-filing. If a company fails to file annual returns or financial statements for 3 consecutive financial years, all directors on the date of default are disqualified from being appointed or continuing as directors in any company in India for 5 years.
Impact of Disqualification
- Cannot be appointed as director in any company for 5 years
- Existing directorships in other companies are affected - the director must vacate office
- DIN is flagged on MCA portal, visible to anyone searching
- Banks reject loan applications from disqualified directors
- Cannot incorporate a new company or LLP during the disqualification period
- Removal requires an NCLT petition even after all filings are completed
How CCFS 2026 Helps
Filing all overdue forms during CCFS 2026 stops the default clock and prevents disqualification from being triggered. For directors already disqualified, completing all filings under the scheme is a prerequisite for the NCLT petition for removal of disqualification. The completed filings serve as documentary evidence that the default has been rectified.
Director disqualification under Section 164(2) is a personal liability that follows the individual, not the company. If you are a director in multiple companies and one defaults for 3 years, your directorships in all companies are affected. Use CCFS 2026 to clear defaults in every company where you hold a directorship.
Post-Filing Actions
Filing overdue forms is step one. Follow these actions to maintain compliance going forward.
Track ROC Approval
After submission, the ROC reviews each form. Approval takes 7 to 15 working days. Check the status under View Submitted Forms on the MCA portal. If ROC raises observations (Resubmission Required), address deficiencies and resubmit within the specified timeline (usually 15 days). If the CCFS 2026 window is still open, resubmissions retain the reduced fee. Retain all SRN receipts and payment confirmations as documentary proof of timely filing under the scheme.
Verify Compliance Status
Once all forms are approved, the company status should change from Active-non-compliant to Active (compliant). If the status does not update within 7 days of the last form approval, raise a grievance on the MCA portal or contact the regional ROC office. Download the updated Master Data and Company Profile from MCA as proof of compliance. Active (compliant) status is essential for filing new event-based forms, obtaining compliance certificates from Company Secretaries, applying for bank loans, participating in government tenders, and entering formal contracts where MCA due diligence is conducted.
Update Company Records
After the compliance backlog is cleared, update any other pending records: (1) verify the registered office address is current on MCA (file INC-22 if changed), (2) confirm all current directors are listed correctly in the company's MCA profile, (3) ensure the auditor appointment is current and ADT-1 is filed for the latest financial year, and (4) update the company's internal board resolution register to reflect all retroactive filings made under CCFS 2026.
Set Up a Compliance Calendar
Prevent a repeat backlog with reminders 30 days before each deadline:
- 15 days from AGM: ADT-1 (auditor appointment)
- 30 days from AGM: AOC-4 (financial statements)
- 60 days from AGM: MGT-7/MGT-7A (annual return)
- 30 September: DIR-3 KYC for all directors
- 31 October: ITR-6 (income tax return for companies)
Annual Compliance Going Forward
Your ongoing obligations depend on the pathway chosen under CCFS 2026:
| Requirement | Active Company | Dormant Company | Struck-Off Company |
|---|---|---|---|
| Annual Return | MGT-7/MGT-7A required annually | Not required (MSC-3 instead) | Not applicable |
| Financial Statements | AOC-4 required annually | Not required | Not applicable |
| Dormancy Form | Not applicable | MSC-3 annually | Not applicable |
| Statutory Audit | Required annually | Not required | Not applicable |
| Board Meetings | Min 4/year (2 for small cos) | Not required | Not applicable |
| Annual Cost | Rs. 15,000 to Rs. 50,000 | Rs. 3,000 to Rs. 8,000 | Nil |
Stay Compliant After CCFS 2026
Annual compliance packages from IncorpX cover audit, ROC filing, ITR, and director KYC. Never miss a deadline again.
View Annual Compliance PlansReconstructing Books for Overdue Years
Companies with multi-year backlogs often have incomplete books of accounts. This is the most time-consuming part of amnesty filing but is solvable.
Sources for Reconstruction
- Bank statements: Complete record of all cash inflows and outflows for company accounts
- GST returns: GSTR-3B and GSTR-1 contain monthly turnover and tax data. Download from GST portal
- TDS certificates (Form 26AS/AIS): Download from Income Tax portal to identify payments received and TDS deducted
- Invoices and purchase orders: Collect whatever sales and purchase records are available
- Previous year filings: Use as opening balance for the next year's reconstruction
- Loan documents: Amortisation schedules from lenders for loan accounts
Reconstruction Process
- Collect bank statements for all company accounts for the entire overdue period
- Download GST return data (GSTR-3B summaries) for monthly turnover figures
- Map bank transactions to sales, purchases, expenses, and capital transactions
- Reconcile GST data with bank data
- Prepare trial balance for each financial year
- Generate Balance Sheet and Profit and Loss Account from the trial balance
- Apply depreciation per Schedule II of the Companies Act, 2013
- Issue audit report for each reconstructed year
Reconstruction adds 7 to 15 working days per financial year. For companies with minimal transactions (under 50 entries per year), a CA can reconstruct in 3 to 5 days. Budget Rs. 5,000 to Rs. 15,000 per year for reconstruction plus audit.
Role of Professionals in CCFS 2026 Filing
CCFS filing involves multiple forms across multiple years, each requiring specific certifications.
Chartered Accountant (CA)
Required for: (1) auditing financial statements for each overdue year, (2) affixing DSC on AOC-4 as statutory auditor, (3) preparing nil financial statements for companies with no transactions. Expect CA fees of Rs. 3,000 to Rs. 10,000 per financial year depending on transaction volume.
Company Secretary (CS)
Required for: certifying Form MGT-7 (via Form MGT-8) for companies with paid-up capital exceeding Rs. 10 crore or turnover exceeding Rs. 50 crore. CS certification is not mandatory below these thresholds but is recommended for multi-year filings. CS fees: Rs. 2,000 to Rs. 5,000 per form.
Professional Fee Breakdown
| Service | Fee Range (Rs. per year) | Required For |
|---|---|---|
| Statutory audit (CA) | 3,000 to 10,000 | AOC-4 filing |
| Financial statement preparation | 2,000 to 8,000 | If books are incomplete |
| MGT-7 certification (CS) | 2,000 to 5,000 | Companies above threshold |
| MCA portal filing assistance | 1,000 to 3,000 per form | All forms |
| DIN reactivation | 500 to 1,500 + Rs. 5,000 govt fee | Deactivated DINs |
Bundling all overdue years with a single professional firm reduces total costs by 30% to 45%. The firm learns your entity's financial patterns after the first year and processes subsequent years faster. Engaging separate professionals for each year multiplies coordination overhead.
Penalty Exposure Without CCFS 2026
Understanding the full penalty exposure quantifies the value of the scheme. These are the consequences of continued non-filing without using CCFS 2026.
| Default | Legal Section | Penalty on Company | Penalty on Directors |
|---|---|---|---|
| Late AOC-4 filing | Section 137(3), Companies Act | Rs. 100/day, no cap + additional fee | Rs. 100/day per director in default |
| Late MGT-7 filing | Section 92(5), Companies Act | Rs. 100/day, max Rs. 5 lakh + additional fee | Rs. 100/day, max Rs. 5 lakh per director |
| Non-filing of DIR-3 KYC | Rule 12A, Companies Rules | Not applicable | DIN deactivation + Rs. 5,000 reactivation fee |
| Non-filing for 3 consecutive years | Section 164(2), Companies Act | Strike-off proceedings under Section 248 | Director disqualification for 5 years |
For a Private Limited Company with 2 directors and 3 years of overdue AOC-4 and MGT-7, total penalty exposure under Sections 92(5) and 137(3) exceeds Rs. 2 lakh in daily penalties alone, in addition to the additional filing fees under Section 403. CCFS 2026 eliminates the Section 403 additional fee escalation, which is the largest component of total cost.
Filing During CCFS 2026 vs Filing After the Deadline
| Parameter | During CCFS 2026 | After 15 July 2026 |
|---|---|---|
| Additional fee | 10% of accumulated additional fee (90% waiver) | Full Rs. 100/day per form, no cap |
| Dormant status fee | 50% of normal MSC-1 fee | Full MSC-1 fee |
| Strike-off fee | 25% of normal STK-2 fee | Full STK-2 fee |
| Penalty immunity | Available if filed before notice or within 30 days | Not available |
| Total cost: 3-year backlog (6 forms) | Approx. Rs. 67,500 govt fee | Approx. Rs. 6,58,800 govt fee |
| ROC enforcement risk | Low (filing signals compliance intent) | High (MCA confirmed post-scheme enforcement) |
| Director disqualification risk | Mitigated by filing during window | Continues to accrue |
GST and Income Tax Alongside CCFS 2026
ROC compliance, GST, and Income Tax filings are interconnected. Addressing all three during the CCFS 2026 window is the most efficient approach.
Income Tax
Companies that have not filed ROC returns have likely not filed ITR-6 either. CCFS 2026 does not affect Income Tax penalties under Section 234F (Rs. 5,000 for returns filed after due date) or interest under Sections 234A, 234B, 234C. File overdue ITRs on the e-Filing portal separately. Updated returns under Section 139(8A) can be filed for the two preceding assessment years with 25% to 50% additional tax.
GST
Verify all GST returns (GSTR-1, GSTR-3B, GSTR-9) are filed for the overdue period. Companies with cancelled GST registrations due to non-filing must apply for revocation under Section 30 of the CGST Act. If filing STK-2 for company closure, GST registration must be surrendered and cancellation order obtained first.
Data Consistency
The audited financial statements prepared for AOC-4 form the basis for ITR-6 preparation. Turnover figures must match across AOC-4, ITR-6, and GSTR-9 (annual GST return). Discrepancies trigger scrutiny from the ROC, Income Tax Department, and GST authorities. For example, if AOC-4 reports turnover of Rs. 50 lakh for FY 2023-24 but GSTR-9 for the same year shows Rs. 55 lakh, both the GST Department and Income Tax Department may issue notices seeking clarification. A single professional firm handling all three filings ensures data consistency and avoids cross-departmental discrepancy notices that add cost and complexity. This is especially critical during CCFS 2026 filings because you are filing multiple years at once, and each year must be internally consistent across all regulatory filings. The CA preparing the audit should reconcile all figures across ROC, GST, and Income Tax before any form is submitted.
Handling Companies with Disqualified Directors
When a company's directors are disqualified under Section 164(2), a practical challenge arises: the disqualified director's ability to sign MCA forms. The approach depends on the specific circumstances:
- DIN active, director disqualified: The director can still sign and file overdue forms for the company that caused the disqualification. Disqualification prevents new appointments, not filing obligations for existing companies. Proceed with CCFS 2026 filing normally.
- DIN deactivated (DIR-3 KYC non-filing): File DIR-3 KYC first to reactivate the DIN. Pay the Rs. 5,000 reactivation fee per director. DIN reactivation takes 3 to 5 working days. Then proceed with annual filings.
- No active directors at all: This situation requires legal intervention. File an application with the NCLT for appointment of interim directors or approach the ROC for specific guidance on CCFS 2026 filing.
In all cases, CCFS 2026 reduced fees apply once the director is able to sign and submit forms. Plan the DIN reactivation timeline to fall within the CCFS 2026 window. For directors who want to remove their disqualification after filings are completed, the process involves filing a petition with the NCLT with evidence of all completed filings. The completed CCFS 2026 filings serve as primary evidence that the default has been rectified.
Special Considerations by Entity Type
Private Limited Companies
The largest group of defaulting entities. Focus on completing statutory audit for all overdue years first, as this is the most time-consuming step. Companies with turnover exceeding Rs. 100 crore or paid-up capital exceeding Rs. 5 crore must file AOC-4 in XBRL format.
One Person Companies (OPCs)
File AOC-4 and MGT-7A (simplified annual return). OPCs are exempt from holding AGMs, so the financial statement filing deadline is 180 days from FY end. Many OPCs fall behind because the sole director manages everything without compliance support.
Section 8 Companies (Non-Profits)
Same annual filing obligations as regular companies but often have limited administrative budgets. Many Section 8 companies registered for 12A and 80G benefits must maintain clean compliance records to retain tax exemption status.
Nidhi Companies
Eligible for CCFS 2026. In addition to standard annual filings, Nidhi Companies must file NDH-1, NDH-2, and NDH-3 with the ROC. Standard annual forms (MGT-7, AOC-4) are covered under CCFS 2026. File standard forms first, then address Nidhi-specific filings.
Foreign Companies
Foreign companies with Indian operations file FC-3 (annual accounts) and FC-4 (annual return), both explicitly covered under CCFS 2026. The 90% additional fee waiver applies to both forms.
Pre-Filing Checklist
Confirm readiness before starting the filing process:
- Confirmed company status is Active or Active-non-compliant (not Struck Off or under Section 248 final notice)
- Listed all overdue forms by financial year from MCA compliance dashboard
- Verified all directors' DINs are active (or initiated DIR-3 KYC reactivation)
- Chosen pathway: Fix (regularise), Pause (dormant), or Close (strike-off)
- Engaged a CA for audit of overdue financial years
- Obtained audited financial statements for each overdue year
- Prepared board resolutions authorising the filing
- Verified DSC validity for all signing directors and statutory auditor
- Calculated estimated fees (standard fee + 10% additional fee) for budget approval
- Organised attachments (PDF format, within MCA file size limits)
- If closing: obtained GST cancellation order, prepared indemnity bond and affidavit
- If going dormant: passed special resolution, obtained NOC from secured creditors
Get a Free Compliance Health Check
Not sure how many overdue filings your company has? IncorpX reviews your MCA record and provides a complete filing plan with fee estimates under CCFS 2026.
Request Free Compliance CheckRelated Resources
- CCFS 2026: MCA Amnesty Scheme for Companies - Concise overview of the scheme
- LLP Amnesty Scheme 2026: What LLP Owners Must Know - Why CCFS 2026 does not cover LLPs
- Private Limited Company Annual Compliance - Ongoing annual filing service
- LLP Annual Compliance Service - Form 8, Form 11, and LLP compliance
- ROC Annual Filing Service - Professional ROC filing assistance
- Close Private Limited Company - Company closure service
- Compliance Health Check - Free compliance status review
- DIR-3 KYC Filing - Director KYC verification service
- Annual Compliance Packages - Ongoing compliance management
- MCA V3 Portal - Official Ministry of Corporate Affairs filing portal
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 (MGT-7, AOC-4, ADT-1) at 10% of the penalty, obtain dormant status (MSC-1 at 50% fee), or close the company permanently (STK-2 at 25% fee). The scheme covers all company types under the Companies Act, 2013 and 1956 but does not cover LLPs. Conditional immunity from penalty proceedings under Sections 92 and 137 is available if filings are completed before an adjudication notice or within 30 days of receiving one. File in chronological order (oldest year first, AOC-4 before MGT-7), reactivate deactivated DINs before any annual filings, and start immediately after 15 April 2026 since STK-2 takes 2 to 4 months. The cost of inaction after 15 July exceeds the cost of acting during the scheme window.
Frequently Asked Questions
What is CCFS 2026?
What is the legal basis for CCFS 2026?
Which entities are eligible for CCFS 2026?
Does CCFS 2026 apply to LLPs?
How much can I save under CCFS 2026?
What is the normal ROC late fee without CCFS 2026?
What forms are covered under CCFS 2026?
What are the three pathways under CCFS 2026?
Who cannot avail CCFS 2026?
Can struck-off companies use CCFS 2026?
What immunity does CCFS 2026 provide?
How does the immunity work for ADT-1, FC-3, and FC-4?
In what order should I file overdue forms?
What happens if my DIN is deactivated?
Do I need a CA to file under CCFS 2026?
How long does the filing process take?
Can directors avoid disqualification by filing under CCFS 2026?
What happens if I do nothing after CCFS 2026 closes?
How is CCFS 2026 different from CFSS 2020?
Can I close my company using CCFS 2026?
What is dormant company status under CCFS 2026?
Can a company with pending GST or income tax use CCFS 2026?
Is CCFS 2026 applicable to foreign companies?
What if the ROC rejects a form filed under CCFS 2026?
Do I pay the normal filing fee under CCFS 2026?
Can I claim a refund if I already paid full penalty?
What documents are needed for STK-2 (company closure)?
Where can I check my company's overdue filings?
Has MCA offered similar amnesty schemes before?
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