Defaulted? Don’t Worry MCA Gives You a 2nd Chance
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Missed Your ROC Filings? MCA Offers a Fresh Compliance Window!
If your company has missed ROC filings, annual returns, or compliance deadlines, this is your opportunity to make things right. The Ministry of Corporate Affairs has once again opened a valuable opportunity for companies that have defaulted in filing annual returns or financial statements. Under the compliance framework of the Ministry of Corporate Affairs, defaulting companies and directors are often provided an opportunity to regularize pending filings by paying additional fees and restoring compliance status.
- File pending ROC Form AOC-4, MGT-7, DIR-3 KYC, etc.
- Avoid heavy penalties & disqualification of directors
- Restore company status to “Active.”
- Reduce legal and financial risk.
Statutory Basis of CCFS‑2026:
The CCFS‑2026 has been notified under Section 460 (Condonation of delay) and Read with Section 403 (Additional fee for delayed filing) of the Companies Act, 2013.
Objective of CCFS‑2026:
The primary goals of the CCFS‑2026 are:
- To provide substantial financial relief by reducing additional fees on overdue filings
- To allow companies to update statutory records with minimal cost implications
- To facilitate Dormant Company status for inactive entities
- To enable a cost‑effective voluntary strike‑off for non‑operational companies
- To support clean and accurate data in the MCA registry
- To reduce litigation, adjudication exposure, and compliance risk
Key Benefits Under the CCFS‑2026:
A. Filing of Pending Statutory Documents:
Companies can file overdue returns by paying the normal filing fee, plus only 10% of the applicable additional fee. This represents a significant waiver compared to the usual penalty of INR 100 per day (no upper cap), applicable since 1 July 2018.
B. Option to Apply for Dormant Status
- Application through e‑Form MSC‑1
- 50% of the normal filing fee is payable
- Ideal for companies with no significant business activity and seeking reduced compliance obligations
C. Voluntary Strike‑Off at Concessional Fee
- Application through e‑Form STK‑2
- Only 25% of the applicable filing fee payable
- Offers an economical exit route for inactive or non-operational companies
Key Highlights of The Company Compliance Facilitation Scheme (CCFS‑2026)
The Company Compliance Facilitation Scheme (CCFS‑2026) is a special initiative by the Ministry of Corporate Affairs designed to help defaulting companies regularize pending statutory filings with minimal additional fees. Under the Company Compliance Facilitation Scheme (CCFS‑2026), businesses can now regularize pending filings with significantly reduced additional fees and regain “Active” status.
Eligibility and Exclusions
The scheme is available to all defaulting companies except:
- Companies already issued final strike‑off notice under Section 248
- Companies that have already filed ROC Form STK‑2
- Companies that have applied for dormant status before the scheme
- Companies dissolved due to amalgamation
- Vanishing companies
Immunity From Penalties
The following company should act immediately and avail immunity from penalties. No liability u/s 92 & 137 if filings are completed before adjudication notice or within 30 days of receiving notice. Companies where a final strike-off notice u/s 248 has already been issued. Companies have already applied for strike-off. Post 15 July 2026, the ROC will commence strict action against non‑compliant entities that fail to utilize this compliance window. Immunity Available When:
- Filing is completed before issuance of adjudication notice, or
- Filing is completed within 30 days of receiving such notice
Immunity Not Available When:
- The 30‑day period from adjudication notice has expired
- An adjudication order has already been passed
However, companies may still claim the fee concession under the scheme. For forms like ADT‑1, FC‑3, FC‑4, protection against future penal proceedings may be available, provided no prosecution or show‑cause notice was issued prior to filing.
Scheme Period: 15 April 2026 to 15 July 2026 :
Running from 15 April 2026 to 15 July 2026, the Company Compliance Facilitation Scheme‑2026 allows companies to file overdue documents by paying only a fraction of the usual penalties, helping businesses return to full compliance, avoid the risk of director disqualification, and prevent potential strike‑off actions. This is a powerful opportunity to restore compliance, reduce risk, and protect the credibility of your business. Scheme Validity: Opening Date: 15 April 2026 and Closing Date: 15 July 2026. This is a strictly time‑bound scheme of 3 months and is unlikely to be extended.
Filing of Pending Annual Forms
Forms Eligible Under CCFS‑2026
Companies Act, 2013
- MGT-7 / MGT-7A – Annual Return
- AOC-4 (including XBRL, NBFC, CFS variants) – Financial Statements
- ADT‑1 – Auditor Appointment
- FC‑3 / FC‑4—Foreign Company Compliance
Companies Act, 1956 (Legacy Forms)
- Form 20B, 21A—Annual Return
- Form 23AC / 23ACA (including XBRL) – Financial Statements
- Form 66—Compliance Certificate
- Form 23B—Auditor Information
If your organisation has pending filings such as AOC‑4 (including XBRL & CFS variants), MGT‑7 / MGT‑7A, ADT‑1, FC‑3 / FC‑4, and DIR‑3 KYC and other related forms. This is the ideal window to complete them with minimal financial burden. Defaulting private limited companies, MSMEs, producer companies, OPCs, and inactive companies. Pay normal filing fees + only 10% of additional fees
Dormant Status (Section 455) :
The Company Compliance Facilitation Scheme provides a time‑bound relief window for companies that have delayed filing their annual returns, financial statements, or other mandatory forms under the Companies Act. Inactive companies can file MSC‑1 at 50% of normal fees
Strike-Off Option:
The Ministry of Corporate Affairs compliance window is designed to encourage voluntary compliance rather than punishment. Non-compliance can lead to director disqualification, company strike-off proceedings, inability to raise funds or open bank facilities, and legal consequences under the Companies Act, 2013. Timely corrective action can safeguard your company’s credibility and operations. Companies opting for closure can file STK‑2 at 25% of applicable filing fees.
Expected Post‑Scheme Action by MCA
Upon closure of the scheme on 15 July 2026, the Registrar of Companies is expected to initiate:
- Stricter monitoring of defaulting entities
- Adjudication proceedings for continued non-compliance
- Potential action under Section 248 for non-filing companies
- Penal consequences for directors and responsible officers
We strongly advise all clients to review pending compliances under both the 2013 and 1956 Acts, Utilize this one‑time relaxation window to regularise filings at minimal cost, consider dormant status if business activity is negligible, Opt for voluntary strike‑off where the company is no longer required, and act well before the scheme closure to avoid last‑minute technical delays. If you need assistance with Ministry of Corporate Affairs filings or understanding the Company Compliance Facilitation Scheme (CCFS‑2026), feel free to connect.
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