Complete Guide to MCA's 90% ROC Penalty Waiver Scheme (April-July 2026)
TL;DR - Quick Summary MCA has launched CCFS-2026 (General Circular No. 01/2026, dated February 24, 2026) offering a 90% waiver on ROC late filing penalties. File pending AOC-4, MGT-7, and ADT-1 forms between April 15 to July 15, 2026 by paying only 10% of accumulated additional fees. Inactive companies can opt for dormant status (50% fee) or strike-off (25% fee). No separate application form required - just file on MCA-21 portal. After July 15, 2026, strict enforcement including director disqualification will begin.
Table of Contents
- What is CCFS-2026?
- Key Details and Scheme Duration
- Forms Covered Under CCFS-2026
- Fee Structure and Savings Calculator
- Eligibility and Exclusions
- Three Pathways Under CCFS-2026
- Immunity from Prosecution
- Step-by-Step Filing Process
- Consequences of Not Availing CCFS-2026
- Real Savings Examples
- Frequently Asked Questions
What is CCFS-2026?
The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) is a one-time amnesty scheme introduced by the Ministry of Corporate Affairs (MCA) through General Circular No. 01/2026 dated February 24, 2026. This scheme provides defaulting companies an opportunity to regularise their pending statutory filings with the Registrar of Companies (ROC) at significantly reduced costs.
Under normal provisions of Section 403 of the Companies Act, 2013 read with the Companies (Registration Offices and Fees) Rules, 2014, delayed filing of annual returns and financial statements attracts an additional fee of Rs. 100 per day - with no upper cap. This means a company that missed both AOC-4 and MGT-7 filings for three years could accumulate penalties exceeding Rs. 2 lakh.
CCFS-2026 changes this equation dramatically. Using powers under Section 460 read with Section 403 of the Companies Act, 2013, the Central Government has decided to condone delays by allowing companies to pay only 10% of the accumulated additional fees - effectively a 90% waiver.
Key Details and Scheme Duration
| Parameter | Details |
|---|---|
| Scheme Name | Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) |
| Notification | General Circular No. 01/2026 dated February 24, 2026 |
| Start Date | April 15, 2026 |
| End Date | July 15, 2026 |
| Duration | 3 Months (92 days) |
| Legal Basis | Section 460 read with Section 403 of Companies Act, 2013 |
| Fee Waiver | 90% waiver on additional fees (pay only 10%) |
| Extension Expected | No - MCA has not indicated any extension |
Forms Covered Under CCFS-2026
The scheme covers a comprehensive list of annual compliance forms under both the Companies Act, 2013 and the legacy Companies Act, 1956.
Under Companies Act, 2013:
| Form | Purpose | Applicable To |
|---|---|---|
| MGT-7 | Annual Return | All companies |
| MGT-7A | Annual Return (Simplified) | OPCs and Small Companies |
| AOC-4 | Financial Statements | All companies |
| AOC-4 CFS | Consolidated Financial Statements | Companies with subsidiaries |
| AOC-4 XBRL | Financial Statements in XBRL | Listed and specified companies |
| AOC-4 NBFC (Ind AS) | Financial Statements | NBFCs following Ind AS |
| ADT-1 | Auditor Appointment | All companies |
| FC-3 | Annual Return | Foreign Companies |
| FC-4 | Financial Statements | Foreign Companies |
Under Companies Act, 1956 (Legacy Forms):
Form 20B, Form 21A, Form 23AC, Form 23ACA, Form 23AC-XBRL, Form 23ACA-XBRL, Form 66, and Form 23B are also covered for companies with pending filings from the old regime.
Fee Structure and Savings Calculator
Understanding the fee structure is critical for calculating your actual savings under CCFS-2026.
| Component | Normal Filing | Under CCFS-2026 |
|---|---|---|
| Normal Filing Fee | As per Rules (Rs. 200-600 based on capital) | Full amount payable |
| Additional Fee (Late Fee) | Rs. 100/day (no cap) | Only 10% payable |
| Dormant Status (MSC-1) | 100% filing fee | 50% of normal fee |
| Strike-Off (STK-2) | Rs. 10,000 | Rs. 2,500 (25%) |
Calculation Example:
Scenario: A Private Limited Company has not filed AOC-4 and MGT-7 for 3 years (approximately 1,095 days per form).
Normal Additional Fee Calculation:
AOC-4: 1,095 days x Rs. 100 = Rs. 1,09,500
MGT-7: 1,095 days x Rs. 100 = Rs. 1,09,500
Total Additional Fee: Rs. 2,19,000
Under CCFS-2026:
Total payable: Rs. 2,19,000 x 10% = Rs. 21,900
Savings: Rs. 1,97,100 (90%)
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Eligibility and Exclusions
CCFS-2026 follows a negative list approach - all companies are eligible except those specifically excluded.
Eligible Companies
- Private Limited Companies
- Public Limited Companies
- One Person Companies (OPC)
- Small Companies
- Section 8 Companies
- Producer Companies
- Foreign Companies (FC-3, FC-4)
- MSMEs and Startups
- Companies with multiple years of pending filings
Excluded Companies
- Companies with final strike-off notice under Section 248
- Companies that have already filed STK-2 (strike-off application)
- Companies that applied for dormant status before April 15, 2026
- Companies dissolved through amalgamation
- Vanishing companies (listed by MCA/SEBI)
- Companies with pending court cases related to management disputes
Three Pathways Under CCFS-2026
CCFS-2026 offers three distinct options depending on your company's situation and future plans:
Pathway 1: Regularise and Continue Operations
For active companies that want to clear their compliance backlog and continue business operations.
- File all pending AOC-4, MGT-7, and ADT-1 forms
- Pay normal filing fee + 10% of additional fees
- Company status changes from "Defaulting" to "Active"
- Directors avoid disqualification under Section 164(2)
Pathway 2: Apply for Dormant Status
For inactive companies that want to preserve the legal entity for future use without heavy compliance burden.
- File e-Form MSC-1 under Section 455
- Pay only 50% of normal filing fee
- Dormant companies only need to file Form MSC-3 annually
- Remain on MCA register with minimal compliance
- Can be reactivated later when business resumes
Pathway 3: Strike Off (Closure)
For defunct companies that want to officially close operations and exit the MCA register.
- File e-Form STK-2 for voluntary strike-off
- Pay only 25% of normal filing fee (Rs. 2,500 instead of Rs. 10,000)
- Company must have no pending liabilities
- Requires board resolution authorising closure
- Much better than waiting for ROC compulsory strike-off (which carries criminal liability)
Immunity from Prosecution
One of the most significant benefits of CCFS-2026 is immunity from prosecution and penalties under Sections 92 and 137 of the Companies Act, 2013.
How Immunity Works:
| Scenario | Immunity Status |
|---|---|
| Filing before adjudication notice issued | Full Immunity |
| Filing within 30 days of adjudication notice | Full Immunity |
| Filing after 30 days of adjudication notice | No Immunity - Penalty applies |
| Adjudication order already passed | No Immunity - Must pay full penalty |
Step-by-Step Filing Process
Login to MCA-21 V3 portal and review your company's "Master Data" to identify all overdue forms for each financial year. List AOC-4, MGT-7, and ADT-1 pending for each year.
Confirm your company is not in the exclusion list (no final strike-off notice, no pending STK-2, not dissolved through amalgamation).
Get all pending years' financial statements audited. Auditor can generate UDIN on current date. Conduct board meeting to approve financials and annual returns.
File AOC-4 first (financial statements), then MGT-7 (annual return). The MCA system will automatically calculate 10% additional fees under CCFS-2026 during the scheme window.
Pay normal filing fee + 10% additional fees. Save payment receipts and SRN numbers. Verify company status changes from "Defaulting" to "Active" on MCA portal.
Consequences of Not Availing CCFS-2026
The MCA has explicitly stated in the circular that after July 15, 2026, Registrars of Companies will take strict action against companies that remain non-compliant.
Post-July 15, 2026 Consequences:
- Full Additional Fees Resume: Rs. 100/day per form continues accumulating with no cap
- Director Disqualification: Under Section 164(2), directors of companies with 3+ years of non-filing are disqualified for 5 years. DIN gets deactivated across ALL companies.
- Adjudication Penalties: Section 92(5) penalty up to Rs. 2 lakh for company + Rs. 50,000 per officer. Section 137(3) penalty up to Rs. 10 lakh for company.
- Compulsory Strike-Off: ROC can initiate suo motu strike-off under Section 248 - carries potential criminal liability for directors
- Banking Restrictions: Defaulting company status affects loan applications and current account operations
- Prosecution: Show cause notices and prosecution proceedings under Sections 92 and 137
Real Savings Examples
Example 1: Stalled Startup (4 Years Non-Filing)
Situation: Private Limited Company incorporated in 2022, never commenced operations, 4 years of zero filings.
Normal Penalty: Rs. 100 x 1,460 days x 2 forms = Rs. 2,92,000
Under CCFS-2026: Rs. 29,200 (10%)
Then file STK-2: Rs. 2,500 (25% of Rs. 10,000)
Total Cost: ~Rs. 32,000 | Total Savings: ~Rs. 2,67,500
Example 2: Dormant Family Holding Company (5 Years)
Situation: Private Limited Company with no real activity, 5 years of missed filings.
Normal Penalty: Rs. 100 x 1,825 days x 2 forms = Rs. 3,65,000
Under CCFS-2026: Rs. 36,500 (10%)
Then file MSC-1 for dormancy: 50% of normal fee
Future Compliance: Only Form MSC-3 annually
Example 3: Active MSME (2 Years Backlog)
Situation: Operating Private Limited Company, missed filings for FY 2023-24 and 2024-25.
Normal Penalty: Rs. 100 x 730 days x 2 forms = Rs. 1,46,000
Under CCFS-2026: Rs. 14,600 (10%)
Savings: Rs. 1,31,400 | Directors avoid disqualification
Frequently Asked Questions
No. Unlike CFSS-2020, CCFS-2026 does not require any separate application or registration form. Simply file your pending forms (AOC-4, MGT-7, ADT-1) on the MCA-21 V3 portal during the scheme window (April 15 to July 15, 2026) and pay the reduced fees. Benefits apply automatically.
Yes. There is no stated cap on the number of years. You can file all outstanding annual filings from previous years within the scheme window. The 90% waiver applies to the total accumulated additional fees across all years.
No. CCFS-2026 specifically applies to companies registered under the Companies Act, 2013 and 1956. LLPs have separate compliance requirements under the LLP Act, 2008 and are not covered by this scheme.
Filing pending returns under CCFS-2026 helps directors avoid future disqualification. However, if DIN has already been deactivated due to Section 164(2), directors need to apply for restoration separately after completing all pending filings. The disqualification is not automatically reversed upon filing.
No. Non-conduct of AGM is a separate non-compliance under Section 96 of Companies Act, 2013, which is not covered under CCFS-2026. AGM non-compliance is a compoundable offence requiring a separate application before NCLT.
No. A struck-off company would first need to be restored to the register via NCLT before it can file returns. CCFS-2026 applies only to companies currently on the MCA register.
Form CSR-2 has been integrated into Form AOC-4 on the MCA V3 portal. When filing pending AOC-4 forms under CCFS-2026, the corresponding CSR-2 details can be filed as part of AOC-4 itself with no separate fee.
MCA has not indicated any extension. The circular explicitly states the scheme window is April 15 to July 15, 2026. Plan and complete your filings assuming July 15, 2026 is the absolute deadline.
Conclusion
The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) represents a rare opportunity for defaulting companies to wipe the slate clean at a fraction of normal costs. With a 90% waiver on accumulated late fees, pathways to dormancy and strike-off at reduced rates, and immunity from prosecution, this scheme addresses the compliance paralysis that has trapped thousands of MSMEs, startups, and inactive companies across India.
The window is strictly time-bound: April 15 to July 15, 2026. There is no indication of extension. After July 15, 2026, the MCA has explicitly warned that ROCs will initiate strict enforcement action including full penalties, director disqualification, and compulsory strike-off proceedings.
Whether you want to regularise and continue operations, preserve your company through dormant status, or close it cleanly through strike-off - CCFS-2026 provides the most cost-effective path available. The cost of acting within the window will always be lower than the cost of waiting.
Vistarkriya helps CA/CS professionals and businesses manage compliance efficiently. From automated reminders to client management dashboards, our platform serves 2783+ active businesses across India.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. CCFS-2026 provisions are based on General Circular No. 01/2026 dated February 24, 2026. For specific compliance matters, consult a qualified Company Secretary or Chartered Accountant. Vistarkriya is not responsible for any decisions made based on this information.
Originally published at: Complete Guide to MCA's 90% ROC Penalty Waiver Scheme (April-July 2026)
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