1. Background
The Ministry of Corporate Affairs (MCA) has issued General Circular No. 01/2026 dated 24 February 2026, introducing the Companies Compliance Facilitation Scheme, 2026 (CCFS-2026). The scheme provides a one-time opportunity for companies to regularize delays in filing statutory documents relating to Annual Returns and Financial Statements under the Companies Act, 2013.
Under Section 403 of the Companies Act, 2013, read with the Companies (Registration Offices and Fees) Rules, delayed filings attract additional fees. Since 01st July 2018, such delayed filings attract ₹100 per day as additional fees without any upper cap, resulting in significant financial exposure for companies with long-pending filings.
In response to stakeholder representations and to promote better compliance within the corporate ecosystem, MCA has introduced CCFS-2026 as a compliance facilitation initiative.
2. Objective of the Scheme
The key objectives of the scheme include:
- Improving compliance levels in the MCA corporate registry
- Providing relief from heavy additional filing fees
- Allowing companies to update pending statutory filings
- Enabling inactive companies to opt for Dormant Status or Strike-off
The scheme is therefore designed as both a compliance correction mechanism and a regulatory clean-up initiative.
3. Scheme Period
The scheme will remain operational for three months.
Commencement: 15th April 2026
Closure: 15th July 2026
Companies must complete their filings or applications within this period to avail the benefits under the scheme.
4. Forms Covered under the Scheme
The scheme applies to various forms relating to financial statements and annual returns, including:
Companies Act, 2013 forms
- AOC-4
- AOC-4 XBRL
- AOC-4 CFS
- AOC-4 NBFC (Ind AS)
- AOC-4 CFS NBFC (Ind AS)
- MGT-7
- MGT-7A
- ADT-1
- FC-3
- FC-4
Forms under Companies Act, 1956
- Form 20B
- Form 21A
- Form 23AC
- Form 23ACA
- Form 23AC-XBRL
- Form 23ACA-XBRL
- Form 66
- Form 23B
These forms relate primarily to financial reporting and annual return compliance.
5. Relief Available under the Scheme
CCFS-2026 provides three key options for companies.
(A) Filing of Pending Annual Returns and Financial Statements
Companies may complete their pending filings by paying:
- Normal filing fees, and
- Only 10% of the additional fees otherwise payable
This represents a significant reduction in late filing costs for companies with long-pending filings.
(B) Dormant Company Option
Inactive companies may apply for Dormant Company Status under Section 455 of the Companies Act, 2013.
This requires filing Form MSC-1 and payment of 50% of the normal filing fees applicable under the rules.
Dormant status allows companies to remain on the register while complying with minimal statutory requirements.
(C) Strike-Off Option
Companies that are no longer operational may apply for removal of name from the register of companies by filing Form STK-2.
Under the scheme, only 25% of the applicable filing fees need to be paid for such applications.
This provides a cost-effective exit route for inactive companies.
6. Immunity from Penalty
The scheme also provides relief from penalty proceedings in certain circumstances.
Where the relevant filings are completed:
- Before issuance of notice by the adjudicating officer, or
- Within 30 days from the issuance of such notice
then the proceedings relating to delayed filings under Section 92 (Annual Return) and Section 137 (Financial Statements) may be concluded and no penalty may be levied.
However, where:
- the 30-day period has expired, or
- a penalty order has already been passed,
the liability to pay such penalties will continue.
7. Companies Not Eligible for the Scheme
The scheme does not apply to:
- Companies against which final notice for strike-off has already been issued by ROC
- Companies that have already filed strike-off applications
- Companies that have already applied for Dormant Status
- Companies dissolved pursuant to amalgamation
- Vanishing companies
8. Consequences of Non-Utilization of the Scheme
After the closure of the scheme, the Registrar of Companies may initiate appropriate action against defaulting companies that have not availed the scheme and continue to remain non-compliant.
This may include:
- Adjudication proceedings
- Penalty imposition
- Regulatory action under the Companies Act
9. Practical Considerations for Companies
Companies should evaluate the following before deciding how to utilize the scheme:
- Number of years of pending filings
- Additional fee exposure
- Operational status of the company
- Future business plans
Based on these factors, companies may choose to:
- Regularize compliance
- Convert into a dormant company
- Apply for strike-off
10. Our Advisory Perspective
CCFS-2026 offers companies a valuable opportunity to reset their compliance position.
Organizations with pending ROC filings should proactively review their compliance records and determine the most appropriate course of action during the scheme period.
Early action will help companies:
- Reduce financial exposure arising from delayed filings
- Maintain updated corporate records
Avoid potential regulatory proceedings.