Last reviewed: 25 September 2026. Update (25 September 2026): the CCFS-2026 window closed on 15 September 2026, after a second extension by General Circular 04/2026 dated 31 August 2026. Filings made within the window keep the 10% additional-fee concession and immunity; fresh filings now attract full additional fees. If your company still has unfiled AOC-4s or MGT-7s piling up additional fees at Rs 100 per day per form, this page explains what the scheme offered, what applies now, and how to clear the backlog under the normal regime. The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) — General Circular 01/2026 dated 24 February 2026 — waived 90% of accumulated additional fees and granted immunity from penal action for filings made within the scheme window. That window, originally 15 April to 15 July 2026, was extended to 31 August 2026 (General Circular 03/2026 dated 8 July 2026, issued after the June 2026 MCA data-centre disruption) and then to 15 September 2026.
After 15 September 2026: what applies now
The circular signalled what follows the scheme: resumption of full Rs 100-per-day additional fees, adjudication notices, strike-off under Section 248, and director disqualification under Section 164(2) where annual filings are pending for three consecutive years — which blocks the same individuals from other boards. A company that missed the window still gains by filing now: additional fees accrue daily, and a filing made before an adjudication notice puts the company in a better position than one made after an order.
| Situation | What to do now |
|---|---|
| Active company with one or two years pending | Finalise and audit the accounts, then file AOC-4 and MGT-7 year by year, oldest first, paying the full additional fees |
| Adjudication notice already received | File the pending forms and reply to the notice, explaining the cause of delay; do not let the reply date pass |
| Company inactive and not needed | Consider strike-off under Section 248 after bringing filings up to date where required |
| Company inactive but to be kept | Consider dormant status under Section 455 (MSC-1) |
| Directors at risk of Section 164(2) disqualification | Prioritise the filings that break the three-year run, and check DIN and DSC status first |
Foreign companies and foreign-owned subsidiaries
The scheme also covered FC-3 and FC-4 for foreign companies with an Indian branch, liaison or project office. Those filings, and the annual accounts of Indian subsidiaries of foreign groups, are often the ones that fall behind because the parent's finance team is far away and relies on a local agent who has moved on. If that describes your Indian entity, our outsourced accounting and compliance service for foreign companies and foreign subsidiary accounting, CFO and FEMA support cover the backlog and the ongoing calendar.
What CCFS-2026 covered (historical)
| Category | Forms |
|---|---|
| Annual return | MGT-7, MGT-7A |
| Financial statements | AOC-4, AOC-4 CFS, AOC-4 NBFC, AOC-4 XBRL |
| Auditor appointment | ADT-1 |
| Foreign companies | FC-3, FC-4 |
| Companies Act 1956 legacy | 20B, 21A, 23AC, 23ACA, 66, 23B |
During the window the scheme also priced the exits attractively: MSC-1 (dormant) at 50% of normal fees and STK-2 (strike-off) at 25%. Those concessions ended with the scheme.
What the 90% waiver was worth — a worked example
A private company skipped its FY 2022-23 annual filing. By August 2026 the delay was roughly 950 days beyond the due dates.
| Item | Normal route (applies now) | Under CCFS-2026 (closed) |
|---|---|---|
| AOC-4 additional fees (~950 days × Rs 100) | Rs 95,000 | Rs 9,500 |
| MGT-7 additional fees (~950 days × Rs 100) | Rs 95,000 | Rs 9,500 |
| Normal filing fees (both forms) | As per capital slab | Same (payable in full) |
| Additional-fee outgo | ~Rs 1,90,000 | ~Rs 19,000 |
| Penalty exposure u/s 92/137 | Adjudication possible | Immunity, if filed before notice / within 30 days of notice |
Two or three pending years multiply the cost. Figures are illustrative — exact additional fees depend on each form's due date; we compute form-wise before filing.
How the immunity worked for filings made in the window
- AOC-4 / MGT-7 (Sections 137/92): immunity from penalty where the form was filed before any adjudication notice was issued, or within 30 days of such a notice. If an adjudication order had already been passed, the scheme did not reopen it.
- ADT-1, FC-3, FC-4 and 1956-Act forms: filing within the window protects against prospective penal action, provided no prosecution or show-cause had already been initiated.
- No separate application: unlike older amnesty schemes, there was no immunity form — the filing itself was the claim. Keep the SRNs and challans of scheme filings on record in case a notice is issued later.
Who was kept out
- Companies where final strike-off action under Section 248 was already initiated by the ROC.
- Companies that had themselves filed STK-2 or applied for dormant status.
- Companies dissolved through amalgamation, and vanishing companies.
Action plan for a company with backlog
- Pull the master data and filing history from the MCA portal; list every pending form year-wise.
- Get the pending financial statements audited (audit is a prerequisite for AOC-4 — factor in auditor timelines).
- Check director DINs are active and DSCs valid; complete DIR-3 KYC where lapsed.
- Compute fee outgo form-wise under the normal regime and file in chronological order.
- Diarise the go-forward calendar so the backlog never rebuilds — our ROC annual filing guide covers the regular due dates, and our first-year compliance checklist covers newly incorporated companies.
Frequently asked questions
What was CCFS-2026 in one line?
It was a one-time MCA scheme (General Circular 01/2026 dated 24 February 2026) allowing companies to file long-pending annual returns and financial statements on payment of normal fees plus only 10% of the accumulated additional fees, with immunity from penal action in specified cases. It closed on 15 September 2026.
Which forms were covered under CCFS-2026?
Annual filing forms including MGT-7 and MGT-7A, the AOC-4 family (AOC-4, CFS, NBFC and XBRL variants), ADT-1, foreign-company forms FC-3 and FC-4, and legacy Companies Act 1956 forms such as 20B, 21A, 23AC, 23ACA, 66 and 23B.
What was the last date to file under the scheme?
15 September 2026 — the window has now closed. The original window of 15 April to 15 July 2026 was extended to 31 August 2026 by General Circular 03/2026 dated 8 July 2026, after the MCA data-centre disruption of June 2026, and then to 15 September 2026 by General Circular 04/2026 dated 31 August 2026.
Is immunity available for filings made within the window?
Yes. No separate immunity application was needed — filing the overdue form within the scheme window itself triggered the protection. For Section 92/137 defaults, immunity applied only where the filing happened before an adjudication notice, or within 30 days of one; it did not apply where an adjudication order had already been passed.
Which companies could not use CCFS-2026?
Companies against which final strike-off action under Section 248 had been initiated, companies that had themselves applied for strike-off (STK-2) or dormant status, companies dissolved through amalgamation, and vanishing companies.
What happens now if we still have not filed?
Full additional fees of Rs 100 per day per form apply to filings made after the scheme closed, and the ROC is expected to move to adjudication of penalties, strike-off proceedings under Section 248, and director disqualification under Section 164(2) where three consecutive annual returns are unfiled. Filing the backlog promptly still limits the damage, because additional fees keep accruing daily.
We compute your full additional-fee exposure and file the backlog under the normal regime, or advise on strike-off/dormancy.
ROC Filing ServicesStrike-off AdvisoryGet a backlog assessmentThis article summarises General Circulars 01/2026, 03/2026 and 04/2026 for general information and is not professional advice. Scheme conditions applied form-wise and company-wise; verify your position on current facts before filing. Consult a Chartered Accountant for advice on your specific situation.