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Company Law

CCFS-2026 extended to 31 August: file pending ROC forms at 90% off

The Ministry of Corporate Affairs has extended the Companies Compliance Facilitation Scheme 2026 to 31 August 2026. Companies with pending AOC-4, MGT-7, or MGT-7A filings can now regularise at concessional additional fees (~10% of normal) before normal penalties resume on 1 September 2026.

CH

CA Harun Raaj

Chartered Accountant · Harun Raaj & Associates

Legal basis: Companies (Amendment) Act 2019, Sections 92(5) and 137(3); Ministry of Corporate Affairs General Circular No. 03/2026 dated 8 July 2026 — Effective: 8 July 2026 (extended deadline 31 August 2026). Source: https://taxguru.in/company-law/mca-extended-ccfs-2026-31-august-2026.html. Last reviewed by CA Harun Raaj: January 2026.

If your company has AOC-4 (financial statements), MGT-7, or MGT-7A (annual return) filings pending for earlier financial years, the compliance) window has widened. The Ministry of Corporate Affairs' Companies Compliance Facilitation Scheme 2026 (CCFS-2026), first notified vide General Circular No. 01/2026 dated 24 February 2026, originally closed on 15 July 2026. It has now been extended to 31 August 2026 vide General Circular No. 03/2026 dated 8 July 2026, following restoration of MCA21 capacity after the 5 June 2026 incident. From 1 September 2026, the standard additional fee of ₹100 per day per form resumes, and ROC enforcement action (adjudication and strike-off) is expected to accelerate.

Key point: CCFS-2026 offers concessional additional fees (~10% of normal) and relief from prosecution for covered delays on AOC-4, MGT-7/7A, and ADT-1 filings if submitted by 31 August 2026.

What CCFS-2026 covers and how much you save

The scheme provides relief on three main fronts:

Relief TypeWhat it applies toDeadline
Concessional additional fee (~90% reduction)AOC-4, MGT-7, MGT-7A, ADT-1 filings for any prior financial year31 August 2026
Prosecution reliefDelay in filing the above forms during the covered periodCircular 03/2026 terms apply
Dormant/exit routesMSC-1 (dormant company status) or STK-2 (strike-off application) at reduced fees31 August 2026

The additional fee under the normal regime is ₹100 per day per form. Under CCFS-2026, this is reported at approximately 10% of the standard rate, reducing the financial pain of regularisation by roughly 90%. These savings apply cumulatively across multiple pending years and multiple forms.

Important: CCFS-2026 is a company-law scheme and does not extend to LLP filings (Form-8, Form-11) or director KYC (DIR-3).

The statutory penalties you avoid by filing inside the window

The penalties triggered by late filings are substantial and accrued per form, per year. Understanding their scale makes the scheme's value clear:

Late Annual Return — Section 92(5): The company and every officer in default face a penalty of ₹10,000, plus ₹100 per day of continuing failure. The maximum penalty is ₹2,00,000 for the company and ₹50,000 for each officer in default.

Late Financial Statements — Section 137(3): The company incurs ₹10,000 + ₹100 per day (capped at ₹2,00,000). The Managing Director, Chief Financial Officer, or (if they are absent) the responsible director(s) face ₹10,000 + ₹100 per day (capped at ₹50,000 per person).

For a company two or three financial cycles in arrears, the cumulative additional fees alone — before any prosecution action — run into several lakhs. Filing under CCFS at concessional rates, with relief for the delay, costs a fraction of that exposure.

Who should prioritise filing before 31 August

  • Private companies with one or more years of missed AOC-4 or MGT-7.
  • Startups and one-person companies (OPCs) with pending MGT-7A.
  • Effectively dormant companies seeking a clean regulatory exit via dormant status (MSC-1) or strike-off (STK-2) at reduced fees.
  • Companies under ROC notice regarding pending filings, before adjudication action begins.

Illustrative example

XYZ Private Limited, incorporated in Bengaluru in 2022, did not file AOC-4 and MGT-7 for FY 2022-23 and FY 2023-24 (four forms total across two years). Outside CCFS, the additional fees alone (₹100/day/form × ~730 days × 4 forms) would exceed ₹2.9 lakhs, plus exposure to Section 92(5)/137(3) penalties of up to ₹2,50,000 (company + officers). Filing all four forms under CCFS-2026 before 31 August 2026 at concessional additional fees (~10% of standard rate) plus relief for the covered delay costs roughly ₹30,000 in additional fees, with prosecution liability eliminated for that period. (This illustration assumes a standard default window; actual costs depend on the exact default period and the company's paid-up capital.)

Next steps

By 31 August 2026: File pending AOC-4, MGT-7, MGT-7A, or ADT-1 forms (and, if exiting, MSC-1 or STK-2 applications) with a Chartered Accountant or Company Secretary to capture the concessional additional fee and prosecution relief.

From 1 September 2026: Normal additional fees resume at ₹100 per day per form, and ROC is expected to initiate adjudication and strike-off proceedings for non-compliant companies.

I'm CA Harun Raaj, Visakhapatnam. If your company has pending ROC filings and you're unsure whether CCFS-2026 applies to your situation, reach out — we can review your default period and file end-to-end before the window closes.

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See Also

Frequently Asked Questions

What forms are covered under CCFS-2026?+

CCFS-2026 covers AOC-4 (financial statements and variants), MGT-7 and MGT-7A (annual returns for private and one-person companies), and ADT-1 (audit reports), filed for any prior financial year with a delay. It does not cover LLP filings (Form-8, Form-11) or director KYC (DIR-3).

What is the concessional additional fee under CCFS-2026?+

Under CCFS-2026, the additional fee is reported at approximately 10% of the standard additional fee (₹100 per day per form). This represents a ~90% reduction. Exact percentages should be verified against MCA Circular No. 03/2026 on mca.gov.in before filing.

What penalties does CCFS-2026 relief cover?+

CCFS-2026 provides relief from prosecution and additional fees accrued under Section 92(5) (late annual return) and Section 137(3) (late financial statements) for the covered period and covered forms, provided the company files before 31 August 2026.

What happens if I file after 31 August 2026?+

From 1 September 2026, the scheme closes. Normal additional fees (₹100 per day per form) resume, and the ROC is expected to initiate adjudication proceedings under Section 454 and strike-off action under Section 248 against non-compliant companies.

Can a dormant or inactive company use CCFS-2026?+

Yes. Companies seeking to formalise dormant status (MSC-1) or apply for strike-off (STK-2) can do so under CCFS-2026 at reduced fees by 31 August 2026, providing a cost-effective regulatory exit.

Does CCFS-2026 apply to limited liability partnerships (LLPs)?+

No. CCFS-2026 is a company-law scheme and does not extend to LLP filings (Form-8, Form-11) or LLP compliance.

If I missed only one year of AOC-4, is it worth using CCFS?+

Yes. The concessional additional fee applies from the first day of default. Even a single late AOC-4 or MGT-7 filing typically costs significantly less to regularise under CCFS (~10% of standard rates) than under the normal regime.

Can a company already under ROC adjudication use CCFS-2026?+

The scheme's eligibility and relief scope depend on the specific adjudication stage and sections involved. If your company is under active enforcement action, verify CCFS applicability with a Chartered Accountant or Company Secretary before proceeding.

Topics:CCFS-2026 extended deadlineROC annual filing complianceAOC-4 MGT-7 concessional feescompany additional fees penalty avoidancesection 92(5) section 137(3) complianceprivate company filing arrearsstrike-off dormant company relief

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