CCFS-2026 closes on 15 September. What to check before it does.
The window to clear an ROC filing backlog at a tenth of the additional fee shuts on 15 September 2026. What it covers, what it saves, who cannot use it, and the control that let the backlog build.
What the scheme is.
Most promoters know there is a filing backlog somewhere in the group. It is rarely the operating company. It is the dormant subsidiary picked up in a share deal, the joint venture that never traded, the holding company whose books nobody was asked to close. No revenue, no staff, no owner in the finance function, so the annual filings drift.
The Companies Compliance Facilitation Scheme, 2026, introduced by MCA General Circular No. 01/2026 dated 24 February 2026, allows specified overdue e-forms to be filed at the normal fee plus only 10 per cent of the additional fee, with relief from penalty and prosecution for the defaults regularised. The window was to close on 15 July, then 31 August, and now 15 September 2026 under General Circular No. 04/2026 dated 31 August 2026.
Three extensions in six months invites a bet on a fourth. That is a wager on an administrative decision, placed by a board that is personally exposed if it loses.
What it covers.
The scheme is built around the annual filing chain, not around every form on the portal.
| Forms | What they are | Relief |
|---|---|---|
| AOC-4 and its CFS, XBRL and NBFC (Ind AS) variants | Financial statements, s.137 | Normal fee + 10% of additional fee |
| MGT-7, MGT-7A | Annual return, s.92 | Normal fee + 10% of additional fee |
| ADT-1 · FC-3, FC-4 | Auditor appointment · foreign company filings | Normal fee + 10% of additional fee |
| 1956 Act forms: 20B, 21A, 23AC, 23ACA and XBRL variants, 66, 23B | Legacy annual filings | Normal fee + 10% of additional fee |
| MSC-1 | Dormant status, s.455 | 50% of normal fee |
| STK-2 | Voluntary strike-off, s.248 | 25% of normal fee: Rs 2,500 |
The normal fee stays payable in full on the usual share-capital slab. The concession is on the additional fee, which for AOC-4 and MGT-7 runs at Rs 100 per day per form under Section 403 with no cap. That uncapped daily charge is why the arithmetic gets ugly.
What it saves.
Take a small private company with no annual filings for 2022-23, 2023-24 and 2024-25.
| Year | Form | Due | Days late | Additional fee |
|---|---|---|---|---|
| 2022-23 | AOC-4 | 30 Oct 2023 | 1,051 | Rs 1,05,100 |
| 2022-23 | MGT-7 | 29 Nov 2023 | 1,021 | Rs 1,02,100 |
| 2023-24 | AOC-4 | 30 Oct 2024 | 685 | Rs 68,500 |
| 2023-24 | MGT-7 | 29 Nov 2024 | 655 | Rs 65,500 |
| 2024-25 | AOC-4 | 30 Oct 2025 | 320 | Rs 32,000 |
| 2024-25 | MGT-7 | 29 Nov 2025 | 290 | Rs 29,000 |
| At full rate | Rs 4,02,200 | |||
| Days late | 15 Sep 2026 − due date |
| Additional fee | days late × Rs 100 per form (s.403, uncapped) |
| At full rate | Rs 4,02,200 |
| Under CCFS at 10% | Rs 4,02,200 × 10% = Rs 40,220 |
| Saving | Rs 3,61,980 |
So Rs 4.02 lakh of additional fee becomes Rs 40,220 on one small company with six overdue forms. Across four or five dormant entities in a group it stops being a compliance line item.
Who cannot use it.
- Companies already issued a final strike-off notice under Section 248
- Companies that have themselves applied for strike-off, or were declared dormant before the scheme
- Amalgamated companies, and companies identified as vanishing companies
- Defaults where an adjudication order has already been passed. The order stands
The last one catches people. The scheme rewards the company that comes forward before the Registrar reaches it, and does nothing for the one that waited to be found.
The check to run this week.
A few hours per entity, in this order, because each step decides the next.
| # | Step | Why here |
|---|---|---|
| 1 | Pull MCA master data and the filed-forms index for every entity, including the ones that do not trade | Internal records are the least reliable source. The entities that drift are the ones whose records were never kept |
| 2 | Build a default schedule: one row per form per year, days late, fee at full rate and at 10 per cent | Half an hour, and it is the decision document |
| 3 | Confirm the financial statements can actually be signed | AOC-4 needs adopted accounts. Closing three years of books, holding the AGMs and getting the audit report takes longer than a week. Establish this on day one |
| 4 | Fix the auditor chain: ADT-1, lapsed terms, reappointment | An audit report from an auditor whose appointment is not on record is a second defect on top of the first |
| 5 | Check DIN status for every signatory | A DIN deactivated for an unfiled DIR-3 KYC stops the filing at the signature stage on the last afternoon |
Three routes, and choosing between them.
For an entity with no operations, filing everything is not automatically right. The scheme prices three different exits.
| Route | Use when | Cost |
|---|---|---|
| Regularise AOC-4, MGT-7, ADT-1 | The entity holds an asset, licence or contract, or will trade again | Normal fee + 10% of additional fee |
| Dormant MSC-1 | Kept deliberately, no transactions, lighter annual regime wanted | 50% of normal fee |
| Strike off STK-2 | No assets, no liabilities, no future use | 25% of normal fee: Rs 2,500 |
Two cautions. Dormant status under Section 455 does not erase past defaults, which generally still have to be cleared. And strike-off is closed to an entity already under a Section 248 notice.
After 15 September.
- Additional fee reverts to Rs 100 per day per form, uncapped, still accruing
- Adjudication under Section 454 resumes, on the company and the officers in default
- Penalties under Sections 92 and 137 apply on their own terms
- Registrars can move on suo-motu strike-off under Section 248(1)
- Section 164(2)(a) disqualification continues to run past three continuous years
The control question underneath.
A fee amnesty is a symptom. The question worth asking after the filing is done is why a backlog built for three years inside a group that files its GST returns every month without fail.
The answer is a control design problem, not a diligence problem. GST returns have a monthly cadence, a named owner, a portal that nags and a cash consequence. Annual ROC filings for a non-operating entity have none of those. There is no rhythm to hang them on, the owner is usually the company secretary of a different entity, and nothing bounces when they are missed. The control did not fail. It was never designed.
Three things make it a real control, and none of them is expensive.
- One statutory calendar for the whole group, not one per company. The entities that drift are the ones missing from whichever calendar exists
- A named owner per entity, with a named backup. "The CS handles it" is not an owner when there are nine entities and one CS
- Evidence of filing, filed. SRN and challan saved against the entity and the year, so compliance can be confirmed without a portal visit. If confirming it takes a portal visit, nobody confirms it between audits
That is a small line on an internal audit plan. The Rs 3.62 lakh above is what one missing calendar cost one small company over three years, before anyone counted the director exposure.
Fee computations in this note are illustrative. They assume AGMs due 30 September of the following year with no extension granted, AOC-4 falling due 30 days and MGT-7 60 days thereafter, and additional fee of Rs 100 per day per form under Section 403 with no cap. Days are counted to 15 September 2026. Normal filing fees, which depend on share capital, are excluded from the comparison. Substitute your own dates before using the figures.
Circular numbers and dates are as reported in public commentary on the scheme. Read the circulars on the MCA portal before relying on them for a filing. Nothing in this note is advice on your facts.
Frequently asked
What is the last date for CCFS-2026?
15 September 2026, extended from 31 August 2026 by MCA General Circular No. 04/2026 dated 31 August 2026. The scheme itself was introduced by General Circular No. 01/2026 dated 24 February 2026 and had originally been set to close on 15 July 2026.
Does CCFS-2026 waive the whole filing fee?
No. The normal filing fee stays payable in full on the usual share-capital slab. Only the additional fee is reduced, to 10 per cent of what would otherwise be charged. For AOC-4 and MGT-7 that additional fee runs at Rs 100 per day per form under Section 403 with no cap, which is where the saving comes from.
Which forms are covered by the scheme?
The annual filing chain: AOC-4 and its CFS, XBRL and NBFC (Ind AS) variants, MGT-7 and MGT-7A, ADT-1, FC-3 and FC-4, and the corresponding Companies Act 1956 forms. MSC-1 for dormant status is at 50 per cent of the normal fee and STK-2 for voluntary strike-off at 25 per cent, being Rs 2,500 against Rs 10,000.
Can a company under strike-off use CCFS-2026?
No. A company already issued a final strike-off notice under Section 248, one that has itself applied for strike-off or dormancy before the scheme, an amalgamated company and a company identified as a vanishing company are all outside it. Where an adjudication order has already been passed, that order stands.
What happens to directors if the filings are not made?
Under Section 164(2)(a), a director of a company that has not filed financial statements or annual returns for three continuous financial years is disqualified, and the disqualification follows the individual to every board they sit on. Filing inside the window is what stops the clock.
