Secretarial Insights

May 2026

Index

1	Introduction to CCFS-2026
2	Objective and Background of the Scheme
3	Key Features and Benefits
4	Applicability and Eligibility Criteria
5	Forms Covered Under the Scheme
6	Fee Structure and Additional Fee Relaxation
7	Immunity and Legal Relief Provided
8	Procedure to Avail the Scheme (Step-by-Step)
10	Options for Inactive Companies
11	Important Timelines and Deadlines
12	Key Exclusions / Non-Eligible Cases
13	Practical Challenges and Professional Insights
14	Actionable Checklist for Companies
15	Conclusion (Professional Advisory Perspective)

Companies Compliance Facilitation Scheme, 2026 (Ccfs-2026): A Comprehensive Professional Guide

Introduction to CCFS-2026

The Companies Compliance Facilitation Scheme, 2026 (CCFS-2026) has been introduced by the Ministry of Corporate Affairs (MCA) vide General Circular No. 01/2026 dated 24 February 2026 as a one-time compliance window for defaulting companies.

The Scheme provides an opportunity to regularize pending statutory filings at significantly reduced additional fees, along with certain legal relaxations.

At a Glance – Key Timeline

Notification Date: 24 February 2026
Scheme Commencement: 15 April 2026
Scheme Closure: 15 July 2026

This limited-time window allows companies to bring their compliance records up to date and mitigate potential regulatory consequences.

Objective and Background of the Scheme

CCFS-2026 has been introduced with the following core objectives:

To enhance corporate compliance levels
To reduce the burden of accumulated additional fees
To encourage companies to update statutory records
To ensure that the MCA registry reflects accurate and updated information

From a regulatory standpoint, the Scheme aligns with:

Section 92 – Annual Return
Section 137 – Filing of Financial Statements
Other applicable provisions of the Companies Act, 2013

Key Features and Benefits

Major Benefits under CCFS-2026

Substantial reduction in additional fees:
- Only 10% of the additional fee is payable for delayed filings
No relaxation in normal filing fees
Concessional fees for closure and dormancy options:
- Dormant status: 50% of the normal fee
- Strike-off: 25% of applicable fee
Immunity from penalty/prosecution (subject to conditions)
No separate application required for immunity

Practical Impact

This Scheme significantly reduces financial and legal exposure for companies that have accumulated non-compliances over multiple years.

Applicability and Eligibility Criteria

Eligible Entities

All companies with pending filings

Non-Eligible Entities (Exclusions)

The Scheme is not applicable to:

Companies where final strike-off action is already initiated
Companies that have already applied for strike-off
Companies that applied for dormant status before the Scheme
Vanishing companies
Companies dissolved due to amalgamation

Forms Covered Under the Scheme

Annual Compliance Forms

MGT-7 / MGT-7A (Annual Return)
AOC-4 series, including:
- AOC-4
- AOC-4 CFS
- AOC-4 XBRL
- NBFC variants

Other Forms

ADT-1 (Auditor Appointment)
FC-3 / FC-4 (Foreign Company filings)

Legacy Forms

Form 20B, 21A
Form 23AC, 23ACA (including XBRL variants)
Form 66, Form 23B

Important: The Scheme covers all pending filings, including those for FY 2024–25.

Fee Structure and Additional Fee Relaxation

Particulars	Normal Scenario	Under CCFS-2026
Additional fee for delay	₹100 per day	10% of the total additional fee
Normal filing fee	Applicable	No relaxation
Dormant status (MSC-1)	Full fee	50% of the fee
Strike-off (STK-2)	Full fee	25% of the fee

Illustration

If delay = 300 days

Normal additional fee = ₹30,000
Under Scheme = ₹3,000

Immunity and Legal Relief Provided

Cases Where Full Immunity Applies

If filings under:

Section 92 (MGT-7/7A)
Section 137 (AOC-4 series)

are made:

Before notice, or
Within 30 days of notice

➡ No penalty will be levied

Other Cases

Immunity from prospective penal action
Applicable only if:
- No prosecution filed
- No show cause notice issued before filing

Important Limitation

No immunity for violation of Section 96 (AGM requirement)

Procedure to Avail the Scheme (Step-by-Step)

Step 1: Identify Defaults

Review MCA records
List all pending filings (year-wise)

Step 2: Verify Eligibility

Ensure the company is not under excluded categories

Step 3: Prepare Financial Statements

Get accounts audited
Ensure UDIN compliance (ICAI requirement)

Step 4: Conduct Pending AGMs (if required)

Adopt financial statements

Step 5: File Forms

File applicable e-forms (MGT-7, AOC-4, etc.)
Pay reduced additional fees

Step 6: Evaluate Closure/Dormancy Option

File:
- MSC-1 (Dormant), or
- STK-2 (Strike-off)

Options for Inactive Companies

Dormant Status (Section 455)

Suitable for inactive companies
Benefit: 50% filing fee
Filed via MSC-1

Strike-off (Section 248)

Exit option for non-operational companies
Fee reduced to 25% under the Scheme

Important Condition

As per rules:

Companies must generally file pending returns up to the cessation year
If action under Section 248(1) is initiated (but STK-7 not issued):
- Filing of all pending forms is mandatory

Important Timelines and Deadlines

Event	Date
Scheme Start Date	15 April 2026
Scheme End Date	15 July 2026

Post Scheme:
Non-compliant companies may face:

Penalty proceedings
Strike-off action

Key Exclusions / Non-Eligible Cases

Companies already under the final strike-off stage
Companies that have filed STK-2 prior
Companies already dormant before the scheme
Vanishing companies
Amalgamated/dissolved entities
Limited Liability Partnerships (LLPs)

Practical Challenges and Professional Insights

Common Challenges

Lack of updated financial records
Delay in audit completion
Missing historical data
Director / auditor availability issues
Technical errors in legacy forms

Professional Insights

Start immediately — timeline is limited (3 months)
Prioritize older defaults first
Ensure UDIN compliance to avoid rejection
Maintain proper documentation trail
Evaluate cost vs closure decision

Actionable Checklist for Companies

Immediate Actions

Extract MCA compliance status
Identify pending forms
Check eligibility under the Scheme

Preparation Stage

Finalize books of accounts
Conduct audits (with UDIN)
Hold pending AGMs

Filing Stage

File AOC-4 (all years)
File MGT-7 / 7A
File ADT-1 (if applicable)

Strategic Decisions

Consider Dormant status
Evaluate Strike-off option

Conclusion (Professional Advisory Perspective)

The Companies Compliance Facilitation Scheme, 2026 presents a time-bound and cost-effective opportunity for companies to regularize long-pending statutory non-compliances.

From a Company Secretary’s perspective, the Scheme should not be viewed merely as a fee reduction window, but as a strategic compliance reset mechanism.

Advisory Note

Companies should act proactively and without delay
Non-utilization may result in stringent regulatory action
A structured, professional approach will ensure:
- Full compliance restoration
- Reduced litigation risk
- Improved corporate credibility

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